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The Policy on Personal Data Processing (hereinafter - the ‘Policy’) is developed in accordance with the Federal Law of 27th July 2006 No. 152 "On Personal Data" (hereinafter – ‘Federal Law-152’).
This Policy defines the procedure for the personal data processing and measures to ensure the security of personal data in the NPEI "The British International School" (hereinafter – the ‘Data Controller’) in order to protect the rights and freedoms of a person and a citizen in the processing of his/her personal data, including the protection of the rights to privacy, personal and family secrets.
The following basic concepts are used in the Policy:
The Company is obliged to publish or otherwise provide unlimited access to this Policy on Personal Data Processing in accordance with Part 2 of Article 18.1. of Federal Law-152.
The processing of personal data by the Data Controller is carried out on the basis of the following principles:
The Data Controller performs the processing of personal data upon availability of at least one of the following conditions:
The Data Controller and other persons who have access to personal data must not disclose to third parties or disseminate personal data without the consent of the personal data subject, unless otherwise provided by the Federal law.
For the purposes of information support, the Data Controller can create publicly available sources of personal data of personal data subjects, including directories and address books. In the public sources of personal data there may be included, with the written consent of the personal data subject, his/her surname, name, patronymic, date and place of birth, position, contact phone numbers, e-mail address and other personal data reported by the subject of personal data.
Information on the personal data subject must be deleted from the publicly available personal data sources at any time at the request of the personal data subject, the authorized body for the protection of the rights personal data subjects or by court order.
The processing by the Data Controller of special categories of personal data relating to race, nationality, political views, religious or philosophical beliefs, health status, intimate life is allowed in cases where:
Processing of special categories of personal data, carried out in the cases provided for by Clause 4 of Article 10 of the Federal Law -152, must be immediately terminated if the reasons for their processing have been eliminated, unless otherwise provided by the Federal laws.
The processing of personal data on the criminal record can be carried out by the Data Controller only in cases and in the manner determined in accordance with the Federal laws.
The information that characterizes the physiological and biological characteristics of a person on the basis of which it is possible to establish his/her identity - biometric personal data - can be processed by the Data Controller only upon availability of the written consent of the personal data subject.
The Data Controller has the right to charge the processing of personal data to another person (Data Processor) with the consent of the personal data subject, unless otherwise stipulated by the Federal law, on the basis of a contract concluded with that person. Data Processor is obliged to comply with the principles and rules for personal data processing stipulated by the Federal Law-152 and this Policy.
In accordance with Article 2 of Federal Law of 21st July 2014 No. 242 "On Amending Certain Legislative Acts of the Russian Federation Regarding Specification of the Procedure for Personal Data Processing in Information and Telecommunication Networks" when collecting personal data, including through information-telecommunication "Internet" network, the Data Controller is obliged to provide recording, systematization, accumulation, storage, clarification (updating, modification), extraction of personal data of citizens of the Russian Federation using databases located on the territory of the Russian Federation, except for the following cases:
The Data Controller is obliged to make sure that the foreign state, into whose territory it is intended to transfer personal data, provides adequate protection of the rights of personal data subjects, before the commencement of such transfer.
Cross-border transfer of personal data on the territory of foreign states that do not provide adequate protection of the rights of the personal data subjects may be carried out in the following cases:
The personal data subject decides to provide his personal data and agrees to their processing of his own free will and volition and in his interest. Consent to the processing of personal data may be given by the personal data subject or his representative in any form that allows to confirm the fact of its receipt, unless otherwise provided by the Federal law.
The personal data subject has the right to receive information from the Data Controller concerning the processing of his/her personal data, if such right is not restricted in accordance with the Federal laws. The personal data subject has the right to demand from the Data Controller the specification of his/her personal data, their blocking or destruction in case personal data are incomplete, outdated, inaccurate, illegally obtained or are not necessary for the stated purpose of processing, and also take measures, prescribed by the law, to protect their rights.
Processing of personal data in order to promote goods, works, services on the market by making direct contact with the personal data subject (potential consumer) by means of communication means, as well as for political agitation is allowed only with the prior consent of the personal data subject.
The Data Controller must immediately stop, at the request of the personal data subject, the processing of his/her personal data for the above purposes.
It is prohibited to make decisions based solely on the automated processing of personal data that generate legal consequences with respect to the personal data subject or otherwise affect his/her rights and legitimate interests, with the exception of cases provided for by the Federal laws or with the written consent of the personal data subject.
If the personal data subject considers that the Data Controller processes his personal data in violation of the requirements of Federal Law-152 or otherwise violates his/her rights and freedoms, the personal data subject has the right to appeal against the actions or omissions of the Data Controller to the Authorized body for the protection of the rights of personal data subjects or in court.
The personal data subject has the right to protect his rights and legitimate interests, including compensation for damages and (or) compensation for moral damage.
The safety of personal data processed by the Data Controller is ensured by the implementation of legal, organizational and technical measures necessary to ensure the requirements of the Federal legislation in the field of personal data protection.
To prevent unauthorized access to personal data, the Data Controller uses the following organizational and technical measures:
Other rights and obligations of the Data Controller in connection with the processing of personal data are determined by the legislation of the Russian Federation in the field of personal data.
Employees of the Data Controller who are guilty of violating the rules governing the processing and protection of personal data bear material, disciplinary, administrative, civil or criminal liability in the manner established by the Federal laws.