Privacy Policy

1. INTRODUCTION 

This Privacy Policy describes how the PRIMA Foundation (hereinafter, “PRIMA”) protects the personal data and fulfills what is established in the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (hereinafter, “GDPR”). 

This Privacy Policy explains how the PRIMA Foundation collects, holds and processes personal data based on the following grounds: 

• Consent: processing is based on consent the interested party has given to us; 
• Performance of a contract: processing is necessary for the performance of a contract; 
• Compliance with our legal obligations: processing is necessary for compliance with EU rules, Spanish law and other legal obligations; and 
• Legitimate interests: processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the interested party interests or his/her fundamental rights and freedoms. 

For each category of data subject, it is explained the purpose for which PRIMA collects personal data, how PRIMA controls access to personal data, and the legal grounds for collecting, processing and holding the personal data. 

2. TYPE OF PERSONAL DATA PRIMA COLLECTS, HOLDS AND PROCESSES AND LAWFUL BASIS 

2.1. Category A: personal data related to job vacancies 

The personal data PRIMA collects, holds and process regarding applicants to job adverts are: 

• Name 
• Address 
• Employer 
• Email address(es) 
• Employment history 
• Educational background 
• Any other additional information the applicant may put on his/her CV 

The personal data PRIMA collects, holds and processes under this category is used for shortlisting suitable candidates for vacant positions, inviting candidates for interview, and for drawing up contracts for the selected candidates. 

The applications received are kept in our recruitment inbox or in the platform created to receive the submissions, which is secure, and is restricted to HR and those involved in the selection process committee. On the day of the interview, CVs and application letters of shortlisted 

candidates are given to interviewers of the selection process committee for making references to during the interview. All documents printed for interviewers are shredded immediately after the interview. 

By applying for a vacant position, the interested party has given PRIMA consent to hold and process his/her application. 

2.2. Category B: personal data related to the attendance to events organized by PRIMA 

The personal data PRIMA collects, holds and processes for individuals who are interested in attending the PRIMA Infoday event (or any other event organized by PRIMA): 

• Name 
• Organisation/institution the interested part work for 
• Email address(es) 

The personal data PRIMA collects, holds and processes under this category are used solely for sending the invitation to the PRIMA Infoday (or other PRIMA events) and is accessible only by the PRIMA staff in charge of sending the invitation the event. 

By registering to the PRIMA Infoday (or other PRIMA events) the interested party has given to PRIMA consent to process and hold his/her personal data. 

2.3. Category C: personal data related to PRIMA current and previous employees 

The personal data PRIMA collects, holds and processes for its current and previous employees are: 

• Copy of the passports or other identity documents (and family members if this is the case) 
• Copy of the resident permits and visas (if required) 
• Copy of diplomas and certificates 
• Date of birth and remuneration details 
• References and CV 
• Home address 
• Sick leave details 
• Telephone numbers 
• Country of origin 
• Performance appraisal information 
• BSN number 
• Bank details 

The personal data PRIMA collects, holds and processes under this category are used to sign the labors contracts with PRIMA, for making salary and other statutory payments; complying with statutory obligations; making visa applications (if required); assigning office equipment (mobile phone, laptops, and PCs); creating logins; making honorarium payments; flight bookings; hotel bookings; publishing the information on the website; and ensuring compliance with our internal policies and procedures. 

Access to the personal data regarding personnel records is restricted to PRIMA HR responsible and the Accounting and Financial Manager. All HR related documents are kept in either secured cabinets or in one of our secure computerized systems. 

PRIMA reasons for collecting, processing and holding personal data under this category include: 

• Compliance with legal obligation; 
• Performance of employment contract; 
• Legitimate interests; and 
• Consent. 

The name and job title of PRIMA current employees are placed on the PRIMA website based on consent of PRIMA employees. 

2.4. Category D: personal data related to applicants to PRIMA calls 

The personal data PRIMA collects, holds and processes for applicants who apply on PRIMA calls are: 

• Name 
• Email address 
• Phone number 
• Employer or organisation/institution the applicant works for 

The personal data PRIMA collects, holds and processes under this category are used solely for selecting those proposals that will funded under the PRIMA calls and is accessible only by the PRIMA staff and the independent experts appointed for the evaluation proposals. 

By submitting proposals to the PRIMA calls the applicants has given to PRIMA consent to process and hold his/her personal data for this purpose. 

2.5. Category E: personal data related to professionals (consultants, contractors, freelancers or experts) performing work on behalf of PRIMA 

The personal data PRIMA collects, holds and processes for professionals who work on behalf of the organization are: 

• Name 
• Address 
• Employer 
• Email address(es) 
• Employment history and educational background (CV) 
• Copy of passport 
• Bank details 
• Nationality 

The personal data PRIMA collects, holds and processes under this category are used for recruitment of professionals, making honorarium payments and other justified expenses, and ensuring compliance with our internal policies and procedures. 

Access to the personal data regarding this category is restricted to PRIMA staff, and service providers where required. 

Our reasons for collecting, processing and holding personal data under this category include: 

• Compliance with legal obligation; 
• Performance of contract; 
• Legitimate interests; and 
• Consent. 

Any processing of personal data related to the recruitment of professionals is based on consent. 

PRIMA requests for expressions of interests from experts who are interested in becoming independent PRIMA evaluators. 

Personal data received from applications is entered in PRIMA database of experts. This processing is also based on consent. By completing an application form, the applicant has given PRIMA consent to hold and process your application 

2.6. Category F: personal data related for Board of Trustees, Steering Committee and Scientific Advisory Committee members 

The personal data PRIMA collects, holds and processes for members of the PRIMA Foundation bodies are: 

• Name 
• Professional address 
• Employer 
• Email address(es) 
• Copy of passport 
• Nationality 

The personal data PRIMA collects, holds and processes under this category are used for meeting communications and notifications, making payments of justified expenses, and ensuring compliance with internal policies and procedures. 

Access to the personal data regarding this category is restricted PRIMA staff and service providers where required. 

PRIMA reasons for collecting, processing and holding personal data under this category include: 

• Compliance with legal obligation; 
• Legitimate interests; and 
• Consent. 

3. RETENTION OF DATA 

PRIMA only retains personal data of the aforementioned interested parties if it is necessary in relation to the purposes for which they are collected or otherwise processed. 

4. RIGHTS OF THE INTERESTED PARTY 

In accordance with GDPR the interested party have the following rights: 

4.1. Right of access 

Right of access to personal data; request PRIMA at any time to give access to the personal data. 

4.2. Right of rectification 

Right to request to rectify any errors in to the personal data. 

4.3. Right to erasure 

Right to request to delete personal data if the continued processing of those data is not justified. 

4.4. Right to restriction of processing 

Right to restrict from processing the personal data at any time unless the processing is lawful. 

4.5. Right to object 

Right to object at any time to processing personal data. 

The interested party can exercise his/her rights by contacting PRIMA (see contact information in section 5 below). The interested party also has the right to lodge a complaint with the supervisory authority (Agencia Española de Protección de Datos, https://www.aepd.es/es) regarding the use of personal data by PRIMA. 

5. CONTACT INFORMATION 

If you have any comments, questions, concerns, or a complaint regarding the way PRIMA collects, hold or processes your personal data, please send an email to: [email protected]. 

September, 2018