Privacy Policy

“International British Academy” (hereinafter referred to as the Academy), when processing personal data for the purpose of performing the functions assigned to it by law, respects fundamental human rights and freedoms, including the rights to privacy and family life, personal space and communication. When registering as a student at the Academy, as well as during seminars and various activities, the personal data of students / participants (data subjects) in various forms are processed in electronic and/or physical form.

1. Purpose and scope of the personal data protection policy
The purpose of the “Academy” Personal Data Protection Policy (hereinafter referred to as the Policy) is to provide interested persons (applicants for enrollment in the Academy, current students, graduates (including as recommenders), participants in various activities or others - data subjects) with basic information on how the Academy processes their personal data, protects their rights defined by law, ensures the security of personal data, etc.

This document has been developed to provide data subjects with information on the general rules and principles of personal data processing in the process of seminars / various activities, as well as to provide data subjects with information about their rights and the mechanisms for exercising these rights.

The Policy applies to the Academy’s processing of personal data about individuals (applicants for enrollment in the Academy, current students and graduates, participants in various activities). The Academy processes personal data in accordance with the following basic principles:
• Lawfulness, fairness and transparency
• Purpose limitation
• Data minimization
• Accuracy
• Storage limitation
• Security
• Integrity and confidentiality.
• The Academy is responsible for confirming compliance with the principles of personal data processing at any time (principle of accountability).

Issues not covered by this document are regulated in accordance with the Law of Georgia “On Personal Data Protection” and the current legislation of Georgia.

2. Definition of terms
The terms used in this document have the following meanings:

Personal data - any information that relates to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, by reference to an identifier such as a name, surname, identification number, geolocation data, an identifier for an electronic communication, or a physical, physiological, mental, psychological, genetic, economic, cultural or social characteristic.

Data processing − any operation which is performed on personal data, including collection, retrieval, access, recording, video and/or audio monitoring, organisation, structuring, alignment or combination, storage, alteration, retrieval, retrieval, use, blocking, erasure or destruction, as well as disclosure of data by transmission, disclosure by transmission, dissemination or otherwise making available.

Data blocking − temporary suspension of the processing of personal data.

Data subject − any natural person The person about whom the data is processed.

Video monitoring - processing of visual image data using installed/installed technical means, in particular, video monitoring and/or video recording.

Audio monitoring - processing of sound signal data using technical means, in particular, audio control and/or audio recording.

Photography - processing of photographic material using technical means.

3. Data Subjects
The Academy processes data about the following individuals:
• Individuals wishing to enroll in the Academy
• Students enrolled in the Academy and participating in seminars
• Graduates (including as recommenders)
• Invited guests (experts, representatives of the diplomatic corps, etc.)

4. Personal data processed
The categories of personal data processed by the Academy include:
• Identification data (e.g. name, surname, personal identification number, date of birth)
• Contact data (e.g. phone number, e-mail address, residential address)
• Audio-visual data (e.g. photo/video data taken during a seminar)
The Academy processes personal data of a restricted category, which includes the production of audio recordings of applicants wishing to enroll in the school or during seminars.

5. Sources of personal data collection
The Academy collects data mainly from the following sources:
• From the data subject himself - by filling out an electronic questionnaire when expressing his desire to study at the Academy
• By taking photos/videos during the seminar
• By processing audio data during the seminar

6. Purposes of processing personal data
The Academy processes personal data mainly for the purpose of implementing its civic-educational functions:
• For the purpose of selecting candidate profiles
• For the purpose of promoting the Academy (taking photos/videos and posting them on social media and the official website)
• For the purpose of recording seminar attendance
• For the purpose of producing archive material on the topics discussed at the seminar

7. Legal basis for processing personal data
The Academy processes personal data on the following legal grounds provided for by the Law of Georgia on Personal Data Protection:
• With the consent of the data subject
• Data processing is necessary to consider the data subject's application/make a decision on enrollment in the school

8. Processing of personal data through audio monitoring

During a seminar at the Academy, audio monitoring is carried out, which means making an audio recording of the reports and discussions of the audience and/or invited guests for the purpose of placing the topics discussed at the seminars in the Academy's archive. This document represents the consent of the audience of the seminar/speaker/expert to the processing of data through audio monitoring. The audio recording is stored indefinitely for the purpose of storing archival data. The basis for implementing audio monitoring is the consent given by the data subject, the need to make a recording for the purposes of the Academy's activities, and the Academy's legitimate interest in maintaining an archive of the Academy's activities.

9. Third parties receiving personal data
The recipients of personal data processed at the Academy may be funders of the civil-educational process (embassies, consulates, etc.).

10. Personal data retention periods The Academy stores data indefinitely, unless the data subject requests the termination of the processing of data subjects (does not apply to audio monitoring).

11. Transfer of personal data to another state and international organization The Academy may transfer data of data subjects to funders of the civil-educational process (embassies, consulates, etc.).

12. Data security measures The Academy uses all available means to prevent the processing of personal data in violation of the current legislation of Georgia. Considering that in the modern world, data processing is mainly carried out using information technologies, the school attaches great importance to the improvement and refinement of information technology systems. The school principal or persons authorized by him/her have access to personal data based on the needs of the school.

13. Data subject rights

The data subject may exercise the rights guaranteed by the legislation of Georgia regarding the protection of personal data regarding his/her personal data processed at the school. In accordance with the request of the data subject, the Academy shall ensure:

• To be informed about the processing of data concerning him/her: which data are being processed; the purpose of data processing; the legal basis for data processing; the source(s) of data collection; the period of data storage/criteria for determining the period of data storage; the rights of the data subject; the transfer of data to another state or international organization and the relevant grounds; the category of data recipient(s) and the grounds and purpose of data transfer; automated data processing and its expected results (if any).
• To be informed about the data stored at the Academy about him/her and to receive this data free of charge, except for data for which a fee is provided for by the legislation of Georgia.

• To correct, update, supplement, block, delete, destroy or terminate the processing of data if they are incorrect, inaccurate, incomplete, not up-to-date or if their collection and processing were carried out in violation of the law.
• The right to data portability - to transmit the data to the data subject or to another controller in a structured, commonly used and machine-readable format, where technically feasible.
• Termination and/or destruction of data processing, if they are processed only on the basis of the data subject's consent and there is no other basis for data processing (except for audio recordings)
In accordance with the legislation, the rights of the data subject may be restricted to the appropriate extent if their implementation poses a threat, including:

• State security, information security and cybersecurity and/or defense interests

• Public safety interests

• Crime prevention, crime investigation, criminal prosecution, administration of justice, operational-detective activities

• Important financial or economic (including monetary, budgetary and tax), public health and social security interests of the country

• Professional, including regulated, interests of the data subject To detect and hold accountable violations of professional and ethical norms
• The rights and freedoms of the data subject or others
• Protection of state, commercial, professional and other secrets provided for by law
• Substantiation of a legal claim or objection
On issues related to personal data, the data subject has the opportunity to contact us at the e-mail address: info@cambridge.ge

14. Consent of the data subject
By agreeing to this document, I declare my consent to familiarize myself with the “Personal Data Protection Policy” and grant the “International British Academy” the right to process my personal (including special category) data specified in Chapter 5 of this document for the purposes specified in Chapter 6 of the School. I also grant permission to publish photographs taken during various Academy activities (seminars, trips) with my participation, at my own discretion and solely for the legitimate purposes of the school, on various social networks or the Academy's official website.