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?
The personal information we collect from you is the following:
- your name, date and place of birth, personal ID number, passport/ID card number, ID photo, validity and date of issue of your passport (only for non EU citizens), gender, health certificate (only for incoming students), bank accounts (only for outgoing Erasmus students, faculty members and staff), job title (only for faculty members and staff) and – and other details, if and when required;
- contact data – home address, citizenship, email address, phone/mobile phone number, Skype/Facebook etc.;
- academic history including your GPA, your major, courses that you have taken, activities and achievements in and outside of University, hobbies, level of English (if you are not a native speaker), courses that you would like to take at AUBG, etc.
How do we collect your personal data?
We collect information about you when you:
- request information to be sent to you; apply electronically for Erasmus/ Study abroad or other exchange programs at AUBG;
- submit your Application Form, Transcript of Records, Learning Agreement, Mobility Agreement, International Passport (only for non EU citizens), Motivation letter, CV etc. as part of the application process;
- request documents required for your student visa application (only for non EU citizens);
- provide your personal information to other parties such as your Home University, EU Commission (for Erasmus students only) and others*.
Note: * When we obtain personal data from third party sources, we will look to ensure that the third party has lawful authority to provide us with your personal data.
The basis for processing your information and how we use it
Receiving and processing your personal data through the application process is necessary for the performance of a contract with you or in order to complete your Erasmus mobility period, Study Abroad or exchange semester or short mobility period (for faculty and staff). In this respect, we use your personal data for the following:
- to provide our core teaching and learning services to you, as outlined in AUBG Student Handbook, once you have registered at AUBG;
- to provide you with information and support regarding any issues that you might raise with us relating to you being an Erasmus/ study abroad or other exchange student; to provide library, bookstore, IT and information services;
- to provide student support services (Disability and additional learning support, Advising and Guidance, Visa assistance (only for non EU citizens), Health Centre and psychological services); to ensure students’ safety and security;
- to manage student accommodation;
- to deal with any concerns or feedback you may have;
- to send the ready visa documents by courier to you or your Host University, upon your request (only for non EU citizens);
- to process personal data for other purposes for which you provide it to us.
We may also 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, or because it is necessary for our legitimate interests. In this respect, we may use your personal data for the following:
- to provide you with educational services not listed in the AUBG Student Handbook but which are part of our academic and educational mission;
- to monitor and evaluate the performance and effectiveness of the university, including training and/or monitoring our staff performance;
- to maintain and improve the academic, corporate, financial, estate and human resource; management of the university;
- to promote equality and diversity throughout the university;
- to promote our services (e.g. student/faculty/staff exchange programs, or other similar events);
- 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:
- financial audits;
- audits from EU Commission;
- Human Resource Development Center(Bulgarian National Erasmus Agency);
- ISEP or other study abroad/exchange authority/organization 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 pseudonymisation 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, National Agency for Evaluation and Accreditation, Ministry of Foreign affairs (for visa purposes), Human Resource Development Center (Bulgarian National Erasmus Agency) etc. as part of our legal obligations;
- EU audit and controlling institutions in compliance with the requirements of EU regulation 45/2001;
- external institutions and organizations (your Erasmus/ Study abroad or other exchange program Host University, ISEP, visa-issuing authorities/only for non-EU citizens/ etc.) and online platforms (Mobility tool, OLS, etc.) in compliance with the requirements of the Erasmus/ Study Abroad or other exchange programs.
In cases we need to transfer your personal data to other third parties – donors, US loan institutions, internal and external auditors, insurance companies, etc., you will be notified, and asked for consent; if the data transfer process requires us to do so. In any case, we 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.
How long we keep it?
Personal data collected through the application process and during your Erasmus/ Study Abroad or other exchange semester is stored for a period of five years after you leave AUBG and will be retained according to the legal requirements of the local authorities to maintaining your academic record (including archiving purposes).
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.