Instruct-ERIC Privacy Policy

The privacy and security of your personal data are very important to us. This Privacy Policy explains how and why we use your personal data, and what actions we take so that you can be confident about sharing this information with us.  

This Privacy Policy applies whether you’re a registered member of Instruct-ERIC, Instruct Centre staff, a user of any of our services, if you visit our Websites, or email, phone or write to us or if we are otherwise engaged with you in a contractual relationship. 

Instruct-ERIC, being the data controller for the purpose of this Privacy Policy, complies with the General Data Protection Regulation (Regulation EU of 27 April 2016) and all other data protection laws of the European Economic Area (“EEA”), its respective member states, and any legal instrument for international data transfers, each as applicable, and as may be amended or replaced from time to time (“Applicable Data Protection Legislation”).

The accuracy of your information is important to us. If you change your email address, or if any of the other personal data we hold on you is inaccurate or out of date, please feel free to keep us updated by sending a message to support@instruct-eric.org.

WHO ARE 'WE'?

In this policy, whenever you see the words “we”, “us”, “our”, it refers to Instruct-ERIC, Oxford House, Parkway Court, John Smith Drive, Oxford, OX4 2JY, UK. Instruct-ERIC was established in July 2017 according to European ERIC Council regulation number 723/2009, implementation reference 2017/C 230/01.

When we refer to our “Websites”, we refer to all websites hosted by Instruct-ERIC. These include at least the following domains:

structuralbiology.eu
instruct-eric.org
instruct-eric.eu
instruct-eric.com
instruct-ultra.eu
west-life.eu
fragmentscreen.org

Our Websites give access to the Instruct-ERIC controlled part of the ARIA Portal (hereinafter “Instruct-ERIC Portal”).

If you have any questions relating to this Privacy Policy or how we use your personal data please contact us at GDPR@instruct-eric.org, or send a letter addressed to Instruct Admin Team, Oxford House, Parkway Court, John Smith Drive, Oxford, OX4 2JY, UK.

WHAT PERSONAL DATA DO WE COLLECT?

Personal data is defined as any information or the combination of information that identifies you or can be identified as relating to you personally. Because of the diversity of personal data we might collect on you during the provision of our services, we set out the main categories of those personal data in the next part.

1. PERSONAL DATA YOU SHARE WITH US ONLINE

When registering an account for the first time on the Instruct-ERIC Portal, you will link your ARIA IDSS account to the Instruct-ERIC services. By linking your ARIA IDSS account, we receive your basic contact details and any other information from your ARIA IDSS account you choose to share with us from ARIA IDSS. The basic contact details consist of your first name, last name, and email address. We will also receive your username, randomly generated by the ARIA IDSS for the purpose of confirming your identity on the Instruct-ERIC Portal.

Should you choose to share more personal data with us in order to complete your Instruct-ERIC Portal account information, you will either be able to share the personal data stored on the ARIA IDSS for this particular purpose or to manually enter such personal data on your profile management page of the Instruct-ERIC Portal. These personal data may include among others your address, phone number, email address, home country, professional experience, title, current employment, etc.

Additionally, personal data may be collected from any content you subsequently choose to place on the Instruct-ERIC Portal. This might among others be the case for any additional personal data required in order to apply for activities under the subsections “2b. Applying for access visits, internships, R&D funding, and bursaries”, and “2c. Training courses, events and conferences” offered by Instruct-ERIC. Personal data might, additionally, be collected via surveys offered on the Instruct-ERIC Portal or by your activity and by placing or uploading content to the user forums part of the Instruct-ERIC Portal. Please note that this list is not exhaustive and new functionalities might be added to the Instruct-ERIC Portal in the future.

2. PERSONAL DATA YOU SHARE WITH US OFFLINE

When making use of our services offline, for example when visiting one of our laboratories or when participating in the events we organise, you might be asked to provide supplementary personal data. Furthermore, we might also collect personal data ourselves in connection with the specific activities organised by us, such as conferences or events.

If the offline service offered by us implies a long-term stay at one of our facilities you might be subject to other privacy policies setting out differing rights and obligations in relation to that specific activity or the specific institution making available such activity. Instruct-ERIC is not responsible for the data processed by such third parties unless otherwise provided.

For information about photography and filming at our events, please consult the Instruct-ERIC Photography and Filming Privacy Notice, which can be found in the annex to this Privacy Policy.

3. PERSONAL DATA COLLECTED VIA AUTOMATED MEANS

When you visit our Websites, your personal data will be collected via automated means. This collection of personal data will continue when accessing the Instruct-ERIC Portal. The collected information relates in particular to internal statistics of your usage of our services and might depend on your assigned role when using the Instruct-ERIC Portal.

We use anonymised IP addresses for our Matomo analytics software. However, we do also collect full IP addresses in our server logs, mainly for security reasons.

Please note that we collect personal data via cookies and related technologies. For more information on this topic, we refer to our Cookie Policy .

4. INFORMATION RECEIVED FROM THIRD PARTIES

When offering services we might make use of third-party services, other than ARIA IDSS, that help with the organisation of certain aspects relating to those services which do not take place on the Instruct-ERIC Portal. These third-party services include online ticketing, calendaring, video conferences, and helpdesk enquiries, for example, Eventbrite, Doodle, Zoom, GoToMeeting, and FreshDesk. The particular third parties providing these services to Instruct-ERIC will depend on the specific events taking place and their geographic availability.

HOW WE USE YOUR PERSONAL DATA

The Instruct-ERIC Portal allows for a multitude of actions for the attainment of our goals as a single point of access to technology and expertise for structural biology research. Below we identified for you the main categories of processing purposes of your data, which will differ depending on the nature of our relationship with you and whether and how you interact with our Website(s) and our various services and activities. 

We never sell your information and we will not pass your information on to a third party, except to approved partners that help us provide these services.

1. ACCOUNT LINKING

You receive access to the Instruct-ERIC Portal by linking your ARIA IDSS account to it. For the purpose of linking your account to the Instruct-ERIC Portal and creating your Instruct-ERIC membership, we process your basic account details, consisting of your first name, last name, email address, and your randomly generated username all of which we receive from ARIA IDSS. Furthermore, you are able to transfer additional personal data, which you might have stored on the ARIA IDSS, for the purpose of completing your Instruct-ERIC Portal account.

For this processing purpose, we base ourselves on your explicit and specific consent given by you to the ARIA IDSS in order to enable the transfer of your basic account details, and where applicable additional personal data, to the Instruct-ERIC Portal. If you choose not to share your basic account details, you will be unable to become a member of the Instruct-ERIC Portal.

Note: For users using the legacy login system referred to as “ARIA login” or “Instruct Authentication Service”, your full registration and profile information is implicitly part of your Instruct-ERIC portal account. This login option will be phased out in the coming months and existing users will be migrated to ARIA IDSS.

2. MEMBERSHIP SERVICES

2a. Your Member Account

As an Instruct-ERIC member, we use your personal data in order to provide you with membership services categorised hereinafter and to manage your membership of the Instruct-ERIC Structural Biology Community. We aim to increase collaboration between scientists, share important information about Instruct-ERIC funded opportunities, invite scientists to make research visits to our extensive technology and laboratory equipment, enable peer review of scientific proposals, and host relevant training courses and conferences. Limited personal data may be viewable to fellow Instruct-ERIC members who may wish to add you as a collaborator for a research proposal, assign you a role within the Instruct-ERIC Portal or send you an internal message, as part of your Instruct-ERIC membership.

We provide you with an account in the execution of our contractual relationship and consider it as our legitimate interest for the proper functioning of the Instruct-ERIC Portal to provide our members with limited personal data relating to other members.

2b. Applying for access visits, internships, R&D funding and bursaries

Instruct-ERIC offers its members the opportunity to apply for research infrastructure access visits, internships, R&D funding, and bursaries. Such applications are made by submitting a proposal through an online portal found on the Instruct-ERIC Portal. Your proposals will subsequently be peer-reviewed by other Instruct-ERIC members who are independent scientific experts in the relevant fields. For your application, additional personal data will be required in the form of your research history and biography.

Your personal data shared for the purpose of your application will be kept private and only visible to Instruct Hub and Centre staff and those members who moderate or review your proposal. Additionally, these data will be shared with the facilities associated with your proposal, as described in the Terms of Submission.

We use the personal data you provide for the purpose of reviewing your application, arranging the services, and to communicate with you throughout the process. We process your data on the basis of our contractual relationship as stated in our Terms of Submission. Furthermore, we are required to maintain minimal personal data, gathered for this processing purpose, for the purpose of reporting to our stakeholders, and to comply with UK law relating to financial recording. These data will be pseudonymised or anonymised to the extent possible.

Additionally, as stated in the Terms of Submission, limited personal information in the form of the names and home country of successful applicants will be published on the Instruct-ERIC Websites.

2c. Training courses, events, and conferences

We use the personal data that you provide as a (potential) participant to training courses, events, and conferences for the purpose of managing your attendance. Your data will be used to communicate with you throughout the process, including to confirm that we have received your registration and/or payment, to clarify where we might need more detail to fulfil a booking, to resolve any issues that might arise with your booking, to collect your feedback following the event, and to produce aggregated statistics about event participants. In some cases, limited correspondence may be sent by Instruct-ERIC to participants after the event, to provide follow-up information or information about related activities.

Some of your information may be shared in this context with third parties such as the organisers and contractors for the events who assist us in hosting the event (e.g. caterers, event management tools, payment tools, etc.) but only on a strict need-to-know basis. All of the previous processing activities are based on the legal basis of our contractual relationship concluded when registering for the specific event.

Instruct-ERIC promotes its services to new users at a range of scientific conferences, exhibitions, and events. Interested attendants at such events may consent to receive a one-time email for more information. For these communications, we base ourselves on your consent.

For information about photography and filming at our events, please consult the Instruct-ERIC Photography and Filming Privacy Notice .

2d. Communications

We use personal data to communicate with you about membership services such as funding opportunities, research calls, Instruct-sponsored training events, and general system notifications. For the purpose of communication, we make a distinction between communications relating to the core Instruct-ERIC service and those that are not.

For both types of communication, we will normally contact you via email, although we might occasionally need to write to you or phone you when these other methods of communication are more appropriate in the specific circumstances.

For information about our core membership services, system notifications, and legal communications, we base ourselves on our legitimate interest, or where necessary our legal obligations.

We base ourselves on your consent for communications with you about activities and opportunities which are not part of the core Instruct-ERIC service. The communications include among others the Instruct-ERIC newsletter by email and other, occasional communications with information about news and events in the wider structural biology community. You will be able to set your subscription preferences regarding the newsletter and occasional communications on the Instruct-ERIC Portal by visiting the profile management page on the Instruct-ERIC Portal, or by clicking ‘unsubscribe’ at the end of any news email.

2e. Forums

All members are able to contribute to the discussions on the Instruct-ERIC forums. When you post in the forum your message, your name, and your (optional) avatar will be added to the forum thread. This information is published on the basis of your consent in posting to the forum. As a result, you are able to delete any posts and topics which you have created.

3. REVIEWERS OF INSTRUCT-ERIC ACCESS AND CALLS

If you agree to act as a moderator or reviewer for Instruct-ERIC research proposals, we will first process your personal data for our internal approval process. Once accepted and depending on your assigned role, you will review proposals requesting core access to Instruct-ERIC infrastructure and/or review applications for a specific Instruct-ERIC call. Your user profile will be shared internally with the approved Instruct-ERIC moderators. The approved Instruct-ERIC moderators will also receive access to statistics on your review history and workload on the Instruct-ERIC Portal in order to enable them to distribute reviewing tasks efficiently. Your identity as a reviewer will only be visible to Instruct-ERIC administrators and moderators but will be hidden from the applicants. For the previous, we base ourselves on the legal basis of our legitimate interest to assign competent people to the relevant tasks and to allocate to you the appropriate applications for your specific area of expertise.

4. INSTRUCT-ERIC PERSONNEL

If you work within an Instruct-ERIC Centre, or if you have a role within national Instruct-ERIC groupings, governing bodies or committees, your name and limited personal information may, depending on your internal role, be shared on the Instruct-ERIC Websites and other Instruct-ERIC dissemination materials as appropriate to your role, on the basis of our legitimate interests. Contact details will never be shared online. Instead, other Instruct-ERIC members are allowed to contact you within the Instruct-ERIC Portal internal messaging system if you have an Instruct-ERIC Portal account. Your name, institution, and (optional) avatar will be viewable to Instruct-ERIC administrative staff who may need to assign a role to you on the Instruct-ERIC Portal, as part of the smooth functioning of teams within Instruct-ERIC. We base ourselves on our legitimate interest in this processing activity.

Some of our meetings, events and workshops, will be minuted in order for us to keep records of discussions held, decisions taken, and actions delegated, and is done as our legitimate interest. Recordings of meetings may be taken to assist with minute taking. Where a meeting is being recorded this will be made clear to the participants. In the minutes, participants and apologies will be recorded, and individuals may be referenced in the minute. Minutes will be shared with meeting participants and relevant Instruct-ERIC bodies or committees but may also be shared with external parties as necessary such as advisory boards. You can request the redaction of any reference to yourself in meeting minutes by contacting us.

5. BUSINESS RELATIONS

We hold the names and contact details of individuals acting in their capacity as representatives of their organisations, across the relevant sectors. If the interactions relate to suppliers, contracts, buildings management, IT services, etc., the legal basis is the contract we concluded and/or our legitimate interests to store information on potential partners.

6. PORTAL MANAGEMENT

We regularly monitor the Instruct-ERIC Portal for compliance with the Terms of use, security, and any illegal activities which might take place thereon. This information is held as a legitimate interest for the purposes of detecting and preventing unauthorised system access and ensuring system security. Where illegal activities take place, our legal basis might additionally be derived from our legal duties as the owner of the Portal.

YOUR DATA PROTECTION RIGHTS

Under the Applicable Data Protection Legislation, you are entitled to exercise certain rights in relation to your personal data stored and processed by us.

If you would like further information on your rights or wish to exercise any of the rights listed in this section, please email us at GDPR@instruct-eric.org or write us at Instruct Admin Team, Oxford House, Parkway Court, John Smith Drive, Oxford, OX4 2JY, UK. We ask of you to properly identify yourself when exercising your data protection rights in order to enable us to execute your request within the timeframes indicated.

The exercise of your rights is free of charge and will be executed within one (1) month of the receipt of your request to exercise your rights. This timeframe may be extended with an additional two (2) months for a total length of three (3) months, should your request prove to be particularly complex. If we decide to extend the timeframe, you will always be informed of this decision in due course.

In those cases where we deem your request to exercise your rights manifestly unfounded or excessive, we reserve the right to charge you an administrative fee for the execution of your request or to refuse to act on your request. You will always be informed within the above mentioned timeframe of one (1) month of our decision.

Please note that exercising your right to rectification, right to erasure, right to restrict the processing of your right to object to processing in relation to us, will not necessarily result in the same effect with any of the other organisations part of or making use of the Instruct-ERIC Portal since these other might organisations process your personal data as separate controllers.

Keep in mind that the data protection rights may not apply or not apply in the same manner to you if you are based outside the European Economic Area (EEA) or may be limited in some circumstances by local legal requirements including the Applicable Data Protection Legislation.  However, we strive to maintain the standards set out in the Applicable Data Protection Legislation and this Privacy Policy for all personal data we process.

1. WITHDRAWAL OF CONSENT

You have the right to withdraw your consent at any time where you have previously given us your consent for such processing. Withdrawing your consent will not impact the validity of the lawful processing activities performed on your personal data before exercising your right of withdrawal.

Please note that, should you decide to unlink your ARIA IDSS account from the Instruct-ERIC Portal by simply withdrawing your consent, this will result in the connection between both services being severed. Consequently, the Instruct-ERIC Portal will be unable to draw new data from the ARIA IDSS. However, your personal data stored and processed on the Instruct-ERIC Portal will remain unaltered and all the processing activities as set out in this Privacy Policy will continue as stated unless you take further action regarding your personal data.

2. RIGHT OF ACCESS

You are entitled to request a copy of the data we process and hold on you. If we process and/or hold personal data about you, you will receive a copy of the information in an understandable format together with an explanation of why and how we hold and use it. 

Additionally, you can ask to receive information regarding the recipients or categories of recipients to whom your personal data has been disclosed, including any recipients from third countries, meaning countries outside the EEA. For the personal data sent to third countries, you will be entitled to receive information regarding the appropriate safeguards we have taken in order to ensure the secure processing of your data. For more information regarding the transfer of your personal data to third parties and/or third countries, we refer to the relevant sections below.

3. RIGHT TO RECTIFICATION

You have the right to ask us to correct your personal data. This includes the right to have us correct spelling mistakes, change an address, email addresses, phone numbers, etc.

Additionally, depending on the purposes of the processing, you have the right to complete any incomplete information we process or hold on you.

You are also able to perform the aforementioned actions yourself on visiting the profile management page on the Instruct-ERIC Portal.

4. RIGHT TO ERASURE

You have the right to request the deletion of the personal data we process or hold on you, including your membership to the Instruct-ERIC Portal. We can object to the deletion if the processing of your data is on the basis of contract or is necessary for the exercise of our freedom of expression or information, to comply with legal obligations, for reasons of public interest or for the establishment, exercise or defence of legal claims.

Should you decide to exercise this right to permanently delete your membership to the Instruct-ERIC Portal, you will no longer be able to log in to the Instruct-ERIC Portal or access the other services we provide. These losses relate in particular to the Instruct-ERIC services such as training, internships, open calls, and research visits. You will also lose the historical record of any research proposals or applications for internships or open calls that you may have submitted to Instruct-ERIC during your membership.

5. RIGHT TO RESTRICT THE PROCESSING

You have the right to restrict our processing of your personal data. Please note that in exercising this right the relevant personal data will remain in our possession, but we will not be able to further process it.

6. RIGHT TO OBJECT TO THE PROCESSING

In those cases where we process and collect your personal data based on our legitimate interest, you have the right to object to our processing of such data. Please note that if you decide to exercise your right to object to our processing of your personal data, we have the right to provide you with our legitimate grounds in order to continue the processing of your data. Our decision to continue the processing of your personal data does not preclude you from filing a complaint with the relevant supervisory authority as set out further below.

In those cases where you object to the processing of your personal data for the purpose of receiving core Instruct-ERIC communications, we retain the right to terminate your Instruct-ERIC membership if we consider that under those circumstances we are no longer able to properly provide you our services.

7. RIGHT TO DATA PORTABILITY

You are entitled to receive the personal data we process or hold on you in a structured, commonly used, and machine-readable format. Furthermore, you have the right to have these personal data transmitted to another data controller, unless we consider this action not to be technically feasible.

RETENTION PERIOD

Your personal data are only processed for as long as needed to achieve the purposes which are described above or, when we asked for your consent, up until such time where you withdraw your consent. In this section, we provide you with the information you need to assess how long we will keep your personal data identifiable. As a general rule, we will de-identify or delete your personal data when they are no longer necessary for the purposes outlined above or when the retention period as explained in this article has expired. However, we cannot de-identify or delete your personal data if there is a legal or regulatory obligation or a judicial or administrative order that prevents Instruct-ERIC from de-identifying or deleting them.

All personal data we collect through our interactions with you via the Website(s), the Instruct-ERIC Portal, phone, e-mail, and other digital communication channels we keep for as long as required to communicate with you, but also to keep a historical archive of our communications. This allows us to revert back to earlier communications if you return to us with new questions, requests, remarks, or other input.

Where you may have consented to receive our newsletter, we will keep personal data for this purpose for as long as you remain subscribed to our mailing list and a member of Instruct-ERIC.

All personal data we collect in the context of a contractual relationship with you or the organization you represent, we will keep for the duration of the contractual relationship, and at least until 7 years thereafter. 

We retain the technical data for the period of time necessary for the purposes set out above, including to investigate issues relating to the Instruct-ERIC Portal. We delete any unused technical data collected and processed after 180 (one hundred eighty) days.

TRANSFER OF DATA TO THIRD PARTIES

Please note that your profile information and the content you place on the Instruct-ERIC Portal, such as on the forums, can be viewed by other members of the Instruct-ERIC Portal.

Additionally, moderators and reviewers will receive the necessary information for the execution of the tasks they are assigned on the Instruct-ERIC Portal. These members of the Instruct-ERIC Portal will never be allowed to use the information they receive for any other purpose than the reviewing and/or moderating purpose they were assigned.

Your personal information can be shared with judicial or administrative authorities or any other authorities or third parties, regardless of their qualification under the applicable national law, if the transfer of personal data is necessary or obligatory to fulfil any legal obligations imposed on us by any applicable laws and regulations.

For the functioning of the performance of our services, we can share minimal personal data with external service providers acting as our processors. These external service providers help among others with maintenance, analytics, safety, fraud detection, development, etc. We will always make sure that the appropriate safeguards are put in place in relation to these external service providers, in order to ensure the safe and confidential transfer and storage of any personal data you make available to us.

Please contact us, should you require more information regarding the third-party recipients, so that we can help you, however possible.

INTERNATIONAL DATA TRANSFERS

We ensure that the appropriate safeguards necessary for the safety and security of your personal data are in place for all personal data processed and transferred within the Instruct-ERIC framework, including at our facilities outside the EEA. For this purpose, Instruct-ERIC has concluded the necessary agreements with its members to ensure appropriate safeguards necessary for the safety and security of your personal data. These agreements include the standard data protection clauses adopted by the European Commission.

1. INSTRUCT-ERIC PORTAL DATA

The personal data we collect from you via the Instruct-ERIC Portal can be transferred to or be stored at Instruct-ERIC physical locations which might be established both inside and outside the EEA for the processing purposes as set out in this Privacy Policy.

For a full and updated list of our Instruct-ERIC locations over the world, our associated country members of the Instruct-ERIC framework, including the members qualifying as an international organisation, we invite you to contact us.

2. REVIEWERS AND MODERATORS

In certain cases, research proposals, moderators, and/or peer reviewers may be located outside of the EEA, in which case your proposal data may be transferred outside of the EEA. We will only share data with reviewers outside of the EEA who are based in countries that provide an adequate level of data protection or reviewers who have individually agreed to additional safeguards to protect your personal data. The same measures will apply to any of our staff outside of the EEA who have access to your data in order to provide Instruct-ERIC services and user support. If your visit is scheduled for a research infrastructure Centre outside of the EEA, your personal data will be shared with the Instruct-Centre facilitating your visit. All reasonable steps will be taken to ensure that your data is treated securely and in accordance with this Privacy Policy.

3. EXTERNAL SERVICE PROVIDERS

Lastly, your information might also be shared with external service providers located outside the EEA in order for Instruct-ERIC to be able to perform the processing activities set out above in the most secure manner possible. This is done by only sharing your personal data to external service providers established in third countries which have been deemed to provide essentially equivalent protection of your personal data by the European Commission or, where applicable, by concluding an agreement containing the standard contractual clauses drafted by the European Commission. These external service providers will wherever possible be considered data processors of Instruct-ERIC.

For an updated list of external service providers located in countries outside the EEA, we invite you to contact us via the contact information provided above.

DATA SECURITY

We protect your personal data by providing the appropriate technical and organisational security measures to minimise the risk of data loss, misuse, unauthorised access, unauthorised disclosure, or unauthorised alteration. For this purpose, we use, among others, firewalls, data encryption procedures, and internal authorisation procedures.

These measures are under constant revision and will be updated regularly in order to provide the necessary guarantees.

AMENDMENTS

We may update this Privacy Policy from time to time. But when we do, we’ll let you know one way or another. Sometimes, we’ll let you know by revising the date at the top of the Privacy Policy that’s available on our Websites or through our applications or other tools. Other times, we may provide you with additional notice (such as adding a statement to our Website’s homepage or providing you with an email notification). Modified versions will have an immediate effect unless stated otherwise.

WHAT TO DO IF YOU ARE NOT HAPPY

The Applicable Data Protection Legislation gives you the right to file a complaint with your local supervisory authority (depending on your place of residence, your place of employment or the place of infringement on data protection law) or with the lead Supervisory Authority being the Information Commissioner’s Office (ICO). You can contact the ICO if you have any questions about Data Protection or wish to file a complaint against Instruct-ERIC. You can contact them using their helpline 0303 123 113 or at www.ico.org.uk.

However, we would appreciate it if, prior to filing any complaint, you contact us in order for us to assist you however possible with your request or concern.

USE OF COOKIES ON THE INSTRUCT-ERIC PORTAL

When you visit our Websites or login to the Instruct-ERIC Portal, your computer may be issued with a small file (a "cookie") for the purpose of managing and improving the services on the Website.

You can set your browser to refuse cookies or warn you before accepting them. However, some cookies may be essential to the operation of the site and if you refuse such cookies, then some or all of the Websites may not work properly or may be unavailable to you.

For an up-to-date list of cookies, please refer to our cookie policy.

The following text forms an inherent part of the Instruct-ERIC Privacy Policy but will be a separable document to enable us to easily share its contents with the applicable data subjects. An URL to the document below will be sent in the communications for offline and online events hosted by Instruct-ERIC to the applicable data subjects ahead of the events taking place.

Instruct-ERIC Filming and Photography Privacy Notice

The Applicable Data Protection Legislation states that “Images” (in the context of this document that means photographs/films) of identifiable individuals may count as personal data. For this purpose, a distinction must be made between Images made of individuals or small groups and those made of crowds. Where the Image is made of a crowd the individuals are usually considered not to be individually identifiable. Therefore, the Applicable Data Protection Legislation is unlikely to apply to these Images. Nevertheless, there is no numerical definition of a crowd, therefore professional judgement is required.

What type of personal data is collected? 

Instruct-ERIC may commission photography and/or filming services within its Instruct Centres and any other event it organises or helps organise. These events include scientific conferences, training events, meetings, etc. The photographs and videos are commissioned for use in Instruct-ERIC’s internal and external promotional material or for archival purposes. The data subject appearing on the Images may include staff, speakers, researchers, and conference or meeting participants.  

For what purposes may Instruct-ERIC take photos or film?  

Instruct-ERIC is the data controller for Images taken by Instruct-ERIC staff or by external service providers contracted for this purpose. Instruct-ERIC will use the Images for its core business only. The core business use includes providing educational resources and promoting our services. The primary legal basis for the taking of Images is our legitimate interests.  

The legitimate interest for the taking of Images refers to our right to fulfil our core business. We believe that the taking of Images will in general not adversely affect you as an individual data subject. Because of our lawful basis being our legitimate interests, we are not obligated to ask your consent when the Images are being taken. However, Instruct-ERIC must make reasonable efforts to inform you that photography and/or filming activities are taking place.

Notices relating to the Images being taken (for example via email / Eventbrite / posters etc) will be published to indicate that photography and/or filming is taking place. You have the right not to appear in an identifiable way in Images and can arrange for this by contacting the event organiser or by absenting yourself as appropriate.

 We will ask for your consent in situations where you as an individual or part of a small group (i.e. not a crowd) are a named subject of a video interview, video teaching session, or a particular photography image. In this situation, explicit consent will be collected prior to taking Images, most often by a consent form. If at any point you wish to withdraw your consent or request that Instruct-ERIC stops using your images/ records, please write to GDPR@instruct-eric.org.  

Can I opt-out of being photographed or filmed? 

You have the legal right to ‘opt-out’ of appearing in an Image. The lawful basis of the legitimate interests allows you to object to your data being processed. Instruct-ERIC will accommodate such opt-out requests.

Examples of how to opt-out at the moment of the Images being taken include: 

reading signage to place yourself in a photography-free zone (e.g. when photography is taking place in a lecture theatre) 
choosing to stand out of shot. If the shot encompasses a wide area you may choose to leave the whole area 
choosing not to attend the event 
asking the photographer not to include them.

 How will the Images  be used and how long will they be kept? 

Images will be used for Instruct-ERIC’s core business, which includes the provision of educational resources and the promotion of our services. The resulting Images may, therefore, be published in print, electronically on the internet or the Instruct-ERIC Portal, and on Instruct-ERIC social media accounts. We store the Images for as long as it is necessary and useful for our core business purposes. When we deem the Images no longer necessary or useful for our core business, the Images and their carriers are permanently destroyed. 

The Images for which Instruct-ERIC is the data controller will be stored electronically, and access will be limited to relevant staff members.  

What rights do I have regarding my personal data? 

When we do not ask your consent for the taking of Images, our processing is based on our legitimate interests. This means that you have the right to request to ‘opt-out’ of being photographed or filmed as explained above. If you wish to object to the processing of an Image after it has been taken or published, we invite you to contact GDPR@instruct-eric.org. 

If we take your Image based on your consent, you have the right to at any point withdraw your consent or request that Instruct-ERIC stops using your Images under its control. In order to exercise this right, please write to GDPR@instruct-eric.org. Please note however that the withdrawal of your consent will only affect future use of your Image.

The rights stated under this section do not bring prejudice to your other rights as found in our more general Instruct-ERIC Privacy Policy.

Instruct-ERIC Privacy Policy version 3.4 updated 26.01.2023