EOSC Portal AAI Privacy Policy
Version 1.0, August 1, 2018
This Privacy Policy explains how we, the EOSC Portal AAI service (“We”), treat data bywhich you can be personally identified (“Personal Data”) as a result of your registration for
and use of the EOSC Portal infrastructure (“Infrastructure”).
To enable the Infrastructure to be safe and reliable for your use and to preserve your rights
as a user we adhere to "The EGI Policy on the Processing of Personal Data" (“The Data
Protection Policy”) available in the Appendix below. The Data Protection Policy should alsobe read with reference to other Infrastructure policies available athttps://wiki.egi.eu/wiki/SPG:Documents.

What Personal Data do We process?
We collect and process the following Personal Data to identify you, thereby enabling us togrant you access to the services and resources provided by the Infrastructure:●●●

Data for User authentication○ Identifiers unique to you as released by your authentication service
Data for registration with the EGI CheckIn service and for collaboration management○ Your name○ Your Institute○ Your e-mail address
Data which may be used to grant you access to the services○ Home Institute, Infrastructure and User Community specific information
relating to your affiliations and roles

Purposes of Processing
We process your personal data solely to manage your access to the EOSC Portal AAI
service and other Infrastructure services, including those provided by User Communities, allbound to the same Infrastructure policies.
Your personal data will be used solely for administrative, operational, monitoring, security
and dispute resolution purposes.
Your usage of the Infrastructure will be monitored and records of this use, containing yourPersonal Data, will be stored and used only for the same purposes.

Stored where?
The records of your use of the Infrastructure are stored in secure databases in various
locations at EGI Resource Centres and EGI Operations and Accounting centres, all of whomare bound by the obligations of this Privacy Policy and the Data Protection Policy.

Accessed by whom?
The records of your use may only be accessed by appropriately authorised individuals inEGI/NGI Operations, in the EGI CSIRT and NGI security teams and authorised resource
managers in your User Community.

Retained for how long?
The records of your use of the service(s) will be deleted or anonymised after, at latest, 18months.

Sharing of your Personal Data with others
Your Personal Data will be shared with other authorised Infrastructure participants via
secured mechanisms, only for the purposes given above, and only as far as necessary to
manage your access to the service(s), any only where the recipient has agreed to abide bythis Privacy Policy and the Data Protection Policy.
The records of your use may be shared for security incident response purposes with otherauthorised participants in the academic and research distributed digital infrastructures viasecured mechanisms, only for the same purposes and only as far as necessary to provide
the incident response capability where doing so is likely to assist in the investigation ofsuspected misuse of Infrastructure resources.

Name and Contact details of Data Processor
The EGI.eu Operations Team. (email: ​operations@egi.eu​)

Name and Contact details of the EOSC Portal AAI
Service Data Protection Officer
You can contact our Data Protection Officer (Matthew Viljoen, EGI Operations, email:matthew.viljoen@egi.eu​) to obtain a copy of your Personal Data, request that it is correctedin case of factual error or if you suspect that it has been misused. You can also request that
we stop using your Personal Data but this will affect your access to the Infrastructure.

Appendix: "The EGI Policy on the Processing of
Personal Data"
Introduction
The "EGI Policy on the Processing of Personal Data" (hereafter referred to in this Appendix
as this "Policy" or the "Policy") ensures that data collected as a result of the use of theInfrastructure is processed fairly and lawfully by Infrastructure participants. Some of thisdata, for example that relating to user registration, monitoring and accounting contains“personal data” as defined by the European Union (EU) [R1]. The collection and processingof personal data is subject to restrictions aimed at protecting the privacy of individuals.

Definitions
Infrastructure
The bounded collection of universities, laboratories, institutions or similar entities,
which adhere to a common set of policies [R2] and together offer data processing
and data storage services to End Users.
Participant
Any entity providing, managing, operating, supporting or coordinating one or more
Infrastructure service(s).
Personal Data
Any information relating to an identified or identifiable natural person [R1].
Processing (Processed)
Any operation or set of operations, including collection and storage, which isperformed upon Personal Data [R1].
End UserAn individual who by virtue of their membership of a recognised research community
is authorized to use Infrastructure services.

Scope
This Policy covers Personal Data that is Processed as a prerequisite for or as a result of an
End User’s use of Infrastructure services. Examples of such Personal Data include
registration information, credential identifiers and usage, accounting, security and monitoring
records. This Policy does not cover Personal Data relating to third parties included indatasets provided by the End User or the research community to which they belong as partof their research activity. Examples of such data are medical datasets which may contain
Personal Data.

PolicyBy their activity in the Infrastructure, Participants:

a. Declare that they have read, understood and will abide by the Principles of Personal
Data Processing as set out below.
b. Declare their acknowledgment that failure to abide by these Principles may result in
exclusion from the Infrastructure, and that if such failure is thought to be the result ofan unlawful act or results in unlawful information disclosure, they may be reported tothe relevant legal authorities.

Principles of Data Processing
i.
ii.

iii.
iv.

v.

vi.

vii.

The End User whose Personal Data is being Processed shall be treated fairly and in
an open and transparent manner.
Personal Data of End Users (hereinafter “Personal Data”) shall be Processed only for
those administrative, operational, accounting, monitoring and security purposes thatare necessary for the safe and reliable operation of Infrastructure services, without
prejudice to the End Users’ rights under the relevant laws.
Processing of Personal Data shall be adequate, relevant and not excessive inrelation to the purposes for which they are Processed.
Personal Data shall be accurate and, where necessary, kept up to date. Where
Personal Data are found to be inaccurate or incomplete, having regard to thepurposes for which they are Processed, they shall be rectified or purged.
Personal Data Processed for the purposes listed under paragraph ii above shall notbe kept for longer than the period defined in a relevant Infrastructure service policy
governing the type of Personal Data record being Processed (e.g. registration,monitoring or accounting) and by default shall be anonymised or purged after aperiod of 18 months.
Appropriate technical and organisational measures shall be taken against
unauthorised disclosure or Processing of Personal Data and against accidental loss
or destruction of, or damage to, Personal Data. As a minimum, Infrastructure
Participants shall:a. Restrict access to stored Personal Data under their control to appropriate
authorised individuals;b. Transmit Personal Data by network or other means in a manner to prevent
disclosure to unauthorised individuals;c. Not disclose Personal Data unless in accordance with these Principals of
Personal Data Processing;d. Appoint at least one Data Protection Officer (DPO) with appropriate training
and publish to the Infrastructure a single contact point for the DPO to which
End Users or other Infrastructure Participants can report suspected breachesof this Policy;
e. Respond to suspected breaches of this Policy promptly and effectively andtake the appropriate action where a breach is found to have occurred;f. Perform periodic audits of compliance to this Policy and make available theresults of such audits to other Infrastructure Participants upon their request.
Each Infrastructure service interface provided for the End User must provide, in avisible and accessible way, a Privacy Policy containing the following elements:

a.
b.
c.
d.

viii.

Name and contact details of the Participant Processing Personal Data;
Description of Personal Data being Processed;
Purpose or purposes of Processing of Personal Data;
Explanation of the rights of the End User to:i.
Obtain a copy of their Personal Data being stored by the Participant
without undue delay;ii.
Request that any Personal Data relating to them which is shown to beincomplete or inaccurate be rectified;iii.
Request that on compelling legitimate grounds Processing of their
Personal Data should cease;
e. The contact details of the Participant’s DPO to which the End User should
direct requests in relation to their rights above;f. Retention period of the Personal Data Processed;
g. Reference to this Policy.
Personal Data may only be transferred to or otherwise shared with individuals ororganisations where the recipienta. has agreed to be bound by this Policy and the set of common Infrastructure
policies,orb. is part of a recognised Computer Incident Response Team framework and as
part of an incident investigation to prevent active or suspected misuse of
Infrastructure services,orc. presents an appropriately enforced legal request.

References[R1]: Directive 95/46/EC of the European Parliament and of the Council of 24 October 1995
on the protection of individuals with regard to the processing of personal data and on thefree movement of such data (DPD)
http://eur-lex.europa.eu/legal-content/en/ALL/?uri=CELEX:31995L0046[R2]: Approved EGI Security Policies. https://wiki.egi.eu/wiki/SPG:Documents