This privacy notice outlines how and why the American University in Bulgaria (AUBG) collects, uses and stores your personal data, and your rights in relation to the personal data we hold. We may modify or amend this Privacy Notice. The most current version will always be available on our Website and, where appropriate, notified to you by e-mail. If you have any questions about such matters you can contact us at [email protected].
What personal data do we collect?
- personal data-name, date, and city of birth, gender, personal identification number(ЕГН/ЛНЧ), student ID number;
- contact data – address, citizenship, email address and phone number; Profile data – specific requests, preferences, feedback, survey responses, application forms;
- academic history data – high school name and address, GPA, grades, activities and achievements in and outside of school, contact information of recommenders, previous university and course (if any) information, etc.;
- family information as part of the application process – name, address, phone number, relationship;
- academic data – grading, GPA, standing, major/minor, course schedule, academic status, test scores, disciplinary actions;
- information on you as a scholar or financial aid receiver.
How do we collect your personal data?
- application materials provided by the Admissions office;
- data submitted per student consent – by mail, e-mail, or in person;
- additional information from sources such as surveys, applications, letters and certificates, evaluations, participation in AUBG’s clubs, councils or committees;
- AUBG page interaction or any web account on AUBG used social media platforms and learning platforms.
How do we use and process the information?
Receiving and processing your personal data is needed to administer the academic process, verify your academic record and diplomas, and is exclusively used during your academic career at AUBG. The information may be stored after you leave AUBG for the purpose of:
- diplomas and degree verification;
- alumni degree conferral requested by state or private institutions (typically done when hiring);
- solicitation letters, award adjustments and academic letter;
- AUBG community updates;
- AUBG Campaigns & Initiatives, special events.
The basis for processing your information and how we use it
We process your personal data because it is necessary for the performance of a contract with you or in order to take steps at your request prior to entering into a contract. In this respect, we use your personal data for the following:
- to provide our core teaching, learning and research services to you, as outlined in AUBG Student Handbook, once you have enrolled at AUBG;
- to administer financial aid and scholarships, according to eligibility requirements;
- to provide library, bookstore, IT and information services;
- to provide student support services (Disability and additional learning support, Careers and Advising Services, Student Medical Centre and psychologist services);
- to ensure students’ safety and security;
- to manage student accommodation;
- to deal with any concerns or feedback you may have;
- to answer your request/s for which you provide your personal data to us.
We may process your personal data because it is necessary for the performance of our tasks carried out in the public interest, as set out in our mission statement and values, which can be found at www.aubg.edu/mission-values, such as:
- tasks that are part of our academic and educational mission;
- to promote equality and diversity throughout the university;
Or process your personal data because it is necessary for our legitimate interests:
- to monitor, maintain and improve the academic, corporate, financial, estate and human resource management of the institution, as well as to evaluate the performance and effectiveness of the university and its staff;
- to promote our services (provide information about summer schools, student exchange programs, or other events happening on and off campus);
- to seek advice on our rights and obligations; to recover money, you may owe to AUBG;
to support our fundraising efforts.
We may also process your personal data in relation to compliance with our legal obligations. In this respect, we may use your personal data for the following:
- maintaining an academic record (including archiving purposes);
- diplomas and degree verification;
- alumni degree conferral requested by state or private institutions;
- financial audits;
- compliance with our regulatory and legal obligations;
- compliance with anti-money laundering laws and safeguarding requirements;
- prevention and detection of crime;
- criminal investigations – assist with investigations (including criminal investigations) carried out by the police and other competent authorities.
We may also process your personal data where:
- it is necessary for medical purposes (e.g. medical diagnosis, provision of health or social care or treatment, or a contract with a health professional);
- it is necessary to protect your or another person’s vital interests;
- or; we have your specific or, where necessary, explicit consent to do so.
Control and care over your data
We, as an institution with one of the highest rankings in Bulgaria, are striving to improve and upgrade our control systems – to include pseudonymization of the collected and processed data, access controls, defined within the university, and most importantly – applied due care by our staff and faculty members. All measures are implemented against inadvertent or deliberate manipulation, loss, or destruction, and access by unauthorized persons.
With whom we share your data?
Your data may be shared with public authorities, such as the Bulgarian Ministry of Education, Ministry of Interior, Ministry of Foreign Affair, Consular Relations Directorate (for visa purposes), National Centre for Information and Documentation (NACID), National Social Security Institute, official University representatives, educational consultants, employment screening services or Universities, internal and external auditors, etc. as part of our legal obligations.
In relation to your scholarship, if any, AUBG may transfer certain details, such as your name, student’s status, academic standing and/or admission score, name of high school, citizenship, CV, photo, major and CGPA, as part of the conditions of the donor, with respect to AUBG’s contractual obligations, for the purposes of administration and reporting of scholarships and grants.
In relation to maintaining and improving the academic, corporate, financial, estate and human resource management of the institution, as well as evaluating the performance and effectiveness of the university and its staff, AUBG may transfer your personal data if and when it finds it appropriate to use subcontractors, i.e. marketing companies for internal and external surveys, evaluation and performance measurement.
With respect to financing your education or additional insurance products, we may need to transfer your personal data to other third parties – US loan institutions, insurance companies, etc.
In any case, when AUBG needs to transfer your personal data to third parties, you will be notified, and asked for consent when the data transfer process requires us to do so. AUBG will share your personal data with high attention to the third parties’ level of technical and organizational ability to manage personal data as required by the GDPR standards.
In compliance with the Family Educational Rights and Privacy Act (FERPA), the American University in Bulgaria will not release student academic information to parents, spouse, or others unless written permission/consent is given by the student. Students may authorize Registrar’s Office to release student’s information by submitting a form for student consent to release information, available on our website: https://www.aubg.edu/documents/215.
The university may share academic records with your parents without your permission if you are under 18 years old.
How long do we keep it?
After graduation, information and personal data regarding the degree conferred is kept permanently. Information is stored and kept according to the legal requirements of the local authorities for maintaining academic record (including archiving purposes). Documents such as requests, declarations, letters, transcripts, certificates, reports, and admissions materials are kept for 5 years after graduation.
The American University in Bulgaria (AUBG) can implement mandatory COVID-19 testing as part of its measures to prevent/limit the spreading of COVID-19 on the territory of the University and with the aim to protect the life and health of its students, employees and visitors. The mandatory COVID-19 testing is based on the legitimate interest of the controller AUBG – Art. 6, p. 1, (f) of the General Data Protection Regulation (GDPR). Please note that the actual testing is carried out in licensed laboratories by medical practitioners and AUBG does not process personal data at that stage. Once presented with information about the medical status of individuals, the processing of this data by the University is based on Art. 9, p. 2, (b) of the GDPR – processing is necessary for the purposes of carrying out the obligations and exercising specific rights of the controller or of the data subject in the field of employment and social security and social protection law in so far as it is authorised by Union or Member State law or a collective agreement pursuant to Member State law providing for appropriate safeguards for the fundamental rights and the interests of the data subject.
The AUBG has chosen tests that are most appropriate for the purposes of the testing and expenses for the tests are covered by the University. The AUBG will apply short retention periods by keeping the data related to the tests only for as long as it is necessary in order to make decisions connected with the purposes mentioned above: preventing/limiting the spreading of COVID-19 on the territory of the University and protecting the life and health of its students, employees and visitors. For your as a data subject in relation to the personal data we hold, pease refer to the last section of this privacy notice.
Collection and use by third party vendors
We do not sell data or databases to third parties for any reason.
You rights in relation to the personal data we hold
- to request access to your personal data we hold;
- to rectify or erasure your personal data; to restrict or object to processing concerning your data;
- to request data transfer to other parties;
- to withdraw consent at any time, without affecting the lawfulness of processing based on consent before this withdrawal;
- to lodge a complaint with the supervisory authority – Commission for Personal Data Protection, address – 2 Prof. Tsvetan Lazarov Blvd., Sofia 1592.
You may address your concerns or inquiries to our Data Protection Officer (DPO) – Gugushev and Partners Law Office, Yoanna Ivanova, e-mail: [email protected]; Address: 11A Aksakov Street, floor 5, Sofia 1000, Bulgaria, Telephone: +359 2 815 75 10.
Please see AUBG Internal Rules for Data Protection for more information.