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Denna tjänst följer det internationella ramverket GÉANT Data Protection Code of Conduct (http://www.geant.net/uri/dataprotection-code-of-conduct/v1) för överföring av personuppgifter från identitetsutfärdare till tjänsten. Ramverket är avsett för tjänster i Sverige, EU och EES som används inom forskning och högre utbildning.

Exempelmall: Transfer of personal data to <name of the service> in connection with federated login (Privacy Policy)

Description of <service name>

The name of the service must be the same as mdui: DisplayName in the service's registered metadata in SWAMID.

Here, the service is described in a good way aimed at users. A core summary of a maximum of 160 characters of the service's description must be registered in mdui: Description in the service's registered metadata in SWAMID.

<Name of the service> is a service directed to <user group> from <examples of organizations>.

<Descriptive text about the service, approx. 1-2 pieces of text>

Handling of personal data

Transfer of personal data

It is important to describe exactly what data is being transferred and its purpose. The information must be clear to the persons for whom the document is intended. The technical representation is used for troubleshooting and should be attribute names defined in the attribute's LDAP specification.

Personal data is transferred from the identity issuer (your login service) to the service to ensure that you as a user have access to your information in the service and to provide you with a user-friendly interface.

In connection with logging in to this service, the following personal data is requested from the identity issuer you use:

In addition to direct personal data, indirect personal data is also transferred, such as which organization the user belongs to and which identity issuer has been used when logging in. In combination with the above personal data, these can be used to uniquely identify a person.

Other processing of personal data in the service

Here it must be described what further processing of personal data and its purpose takes place within the service, for example by entering personal data from the user if the service has a local user profile which the user himself supplements with information that does not come from the identity issuer. It is also about personal data that comes from another source and is linked to the user in the service. Also keep in mind that personal data stored in log files and elsewhere must be described.

Transfer of personal data to third parties

Here it must be described which (if any) transfer of personal data takes place to third parties. Keep in mind that the entity category GÉANT Data Protection Code of Conduct v1.0 (http://www.geant.net/uri/dataprotection-code-of-conduct/v1) imposes severe restrictions on the personal data that may be transferred to third parties.

Excerpt from GÉANT Data Protection Code of Conduct v1.0:

The Service Provider agrees and warrants:

f) [Third parties] not to transfer Attributes to any third party (such as a collaboration partner) except

a. if mandated by the Service Provider for enabling access to its service on its behalf, or
b. if the third party is committed to the Code of Conduct or has undertaken similar duties considered sufficient under the data protection law applicable to the Service Provider or
c. if prior consent has been given by the End User;

Legal basis

This section describes the legal basis under which the Data Protection Regulation (GDPR) processes personal data. The legal basis is linked to the purpose of the proceedings.

Keep in mind that the legal basis for consent places very high demands on voluntariness and can therefore very rarely be used for services that a person uses in their employment or in their studies.

Right to register extract, correction and deletion of personal data

Here, the user's rights according to the Data Protection Regulation (GDPR) must be described. Particularly important is access to personal data, correction of personal data and deletion of personal data.

For register extracts, correction and deletion of your personal data, contact the personal data manager.

Correction of personal data transferred in connection with login is done in the identity issuer that you use to log in. This information is corrected in the service at the first login after the personal information has been corrected in the identity issuer.

Purification of personal data

Here is a general description of the service's regulations on automated cleaning of personal data, incl. how long these are saved when the user no longer uses the service.

Personal data manager

Here, contact routes for the person responsible for personal data and its representative (the person within the organization who is responsible / administrator for the service) are described. Contact routes must also be specified to the organization's data protection officer. OrganizationDisplayName in the service's registered metadata in SWAMID must be the same as the organization name in this section.

The person responsible for personal data for the processing of personal data is <organization>, <land>. If you have questions about how personal data is used and handled within the service, please contact <e-mail address for service representatives>.

Data protection agents are <name>, <organization>, <contact information>. alternatively Contact information for <organization> data protection officer can be found at <URL to information page with contact information for the data protection officer>.

GÉANT Data Protection Code of Conduct

This service complies with the international framework GÉANT Data Protection Code of Conduct (http://www.geant.net/uri/dataprotection-code-of-conduct/v1) for the transfer of personal data from identity issuers to the service. The framework is intended for services in Sweden, the EU and the EEA that are used in research and higher education.