General Information
The Civil Society Development Foundation (hereinafter referred to as “CSDF”, “the Foundation”, “the organization”), with registered office at 21, Bulevardul Nerva Traian, Sector 3, Bucharest, fiscal registration code 14476331 and registered with the Sector 2 Court on the based on Court Decision no. 111 of 21.12.1994, as author, owner and administrator of the website www.fdsc.ro and as “data controller” within the meaning of the rules established by national law and the General Data Protection Regulation – Regulation no. 679 issued by the European Parliament and the Council of the European Union on the protection of individuals with regard to the processing of personal data and the free movement of such data and repealing Directive 95/46/EC, which entered into force on May 25, 2018. CSDF respects the right to privacy of individuals accessing our website and ensures the fair and lawful processing of personal data for all individuals who provide personal data for CSDF.
The purpose of this document is to inform you about the general policy of the Civil Society Development Foundation regarding the collection, processing and storage of your personal data in the framework of its current activities, such as but not limited to: funding programs administered by CSDF, projects implemented by CSDF, business relations and the conclusion of various types of contracts with service providers, authorized or unauthorized individuals, registration to events organized by CSDF and the submission of questionnaires to participants for feedback purposes, visiting CSDF websites, as well as the publication of articles and interviews, including on the website www.fdsc.ro etc.
This Policy lists the personal data that may be processed by CSDF in the course of its activities; however, each type of processing will be handled on a case-by-case basis, so that CSDF will only collect, process and effectively collect those personal data that are necessary to fulfill CSDF’s purposes. Individuals will be directly informed about the processing of their personal data by CSDF in the context of each activity involving the processing of personal data of individuals, respecting the principle of minimizing the data to be processed (only that data that is adequate, relevant and limited to what is necessary in relation to the purposes for which the personal data is processed) and will obtain the consent of individuals where required by applicable regulations.
- Processing of personal data of representatives of organizations applying online for funding
- Categories of personal data that may be processed
Through the websites of the CSDF, which cover the various funding programmes administered and implemented by the Foundation, where the Grant Application Form is provided, a series of personal data is collected from contact persons, persons with the right to represent, members of the Board of Directors, staff of the applicant organization that will be involved in the project, persons from partners – organizations or institutions – working with the organizations applying for funding. These personal data can be: name, surname, function, telephone, e-mail, signature, CV, professional experience, role in the project, in relation to the members of the Governing Board the following categories of data are collected in addition: membership of an organization/institution/company/political party.
Purposes and grounds for processing
In order to establish the background of the interaction with the applicant organization, the CSDF collects a series of personal data belonging to contact persons, members of the Board of Directors and staff of the applicant organization.
CSDF has an interest in obtaining as much relevant information as possible on applicant NGOs for the following reasons:
● Designation as winner of the NGO which offers the best guarantees that it can implement the project (e.g. staff involved who have experience in the field of the project);
● Justifying the choice to the funder.
About the transfer of personal data
The present personal data exchanged between the operator (CSDF) and third parties may be transferred outside Romania, depending on the program for which the beneficiary applies. In addition, they may be transferred to the main funders of the different projects and/or auditors at the request of the main funders.
Data retention period
The data retention period will be established on the instructions provided by the funder and for a period necessary to keep the personal data relevant for the purpose mentioned in point B. This will be highlighted and specified precisely within each grant contract for which the organizations will apply.
- Processing the personal data of various persons connected with the NGOs applying for funding in order to assess the previous relationship with the NGO concerned
- Categories of personal data processed
Personal data belonging to representatives, contact persons, board members, staff involved in the project within the applicant organization are collected by CSDF in order to assess the previous relationship with the NGO. This personal data can be: name, surname, position, telephone, e-mail, signature, CV, professional experience, role in the project.
Purposes and grounds for processing
In order to establish the background of the interaction with the representative of the applicant organization, CSDF collects a series of personal data belonging to that representative. CSDF’s legitimate interest in verifying how the working relationship between CSDF and the applying organization (if such interaction has existed in the past) has been conducted in the past. Thus, by analysing the past relationship and the organization’s background, it can be established whether the NGO in question provides sufficient guarantees for the proper implementation of the funded projects for which it is applying.
About the transfer of personal data
The present personal data between the operator (CSDF) and the authorized persons (third parties) may be transferred outside Romania, depending on the program for which the beneficiary applies. In addition, they may be transferred to the main funders of the different projects.
Data retention period
The data retention period will be in accordance with the instructions of the funder and for a period necessary to keep the personal data relevant for the purpose mentioned in point B.
III. Processing of personal data of NGO representatives of NGOs benefiting from funding projects for establishing the background of the NGO representative
Categories of personal data processed
Personal data belonging to project beneficiaries (organization representatives) is collected by CSDF for the purpose of determining how the organization representative has interacted with CSDF on their own behalf or on behalf of other organizations they have represented (other than those whose representative they currently represent). This personal data may include: first name, last name, title, telephone, e-mail, signature, CV, professional experience, role in the project.
Purposes and grounds for processing
In order to establish the background of the interaction with the representative of the applicant organization, the CSDF collects a series of personal data belonging to this representative. Personal data belonging to project beneficiaries (organization representatives) is collected by CSDF for the purpose of establishing how the organization representative has interacted with CSDF on behalf of themselves or on behalf of other organizations they have represented (other than those whose representative they currently represent).
About the transfer of personal data
The personal data between the operator (CSDF) and the authorized persons (third parties) may be transferred outside Romania, depending on the program for which the beneficiary applies. In addition, they may be transferred to the main funders of the different projects.
Data retention period
The data retention period will be in accordance with the instructions of the funder and for a period necessary to keep the personal data relevant for the purpose mentioned in point B.
- The processing of personal data in relation to organizations that are designated as the winner of a particular grant project
- Categories of personal data processed
In order to demonstrate the activities carried out for the implementation of the funded projects, the organizations submit a series of personal data to the CSDF, through specific documentation, such as technical and financial reports, supporting documents, etc. The data submitted are intended for several categories of data subjects: project beneficiaries (target group), outsourced experts, project implementation team, members of the Board of Directors of the organization. These personal data may be: name, surname, function, personal numeric code, salary (full or partial), address, bank account, copies of supporting documents of employment and payment related to the expenses requested for reimbursement (e.g. individual employment contracts, copyright contracts, service contracts, pay slips, payment orders, salaries and contributions, payment orders, experts’ fees, invoices, receipts, contracts with service providers related to events organized within the projects).
Purposes and grounds for processing
The legitimate interest of CSDF is to monitor the actual implementation of the funded project. CSDF has an interest in verifying how the project is being or has been implemented in comparison with the initial details provided at the time the funding was granted.
About the transfer of personal data
The present personal data between the operator (CSDF) and third parties, may be transferred outside Romania, depending on the program for which the beneficiary applies. In addition, these personal data may be transferred to the following categories of persons: funders/sponsors, evaluators and/or auditors on the occasion of controls carried out by them, tax authorities and other public authorities in case of a potential control by them, CSDF’s partners in case a project is being worked on within a consortium, lists/information about the representatives of the winning NGOs made public on the website.
Data retention period
The data retention period will be in accordance with the instructions of the funder and for a period necessary to keep the personal data relevant for the purpose mentioned in point B.
- Processing of personal data in relation to service providers
- Categories of personal data processed
The personal data belonging to service provider contacts that may be collected by CSDF are: name, surname, organization name, function, telephone, e-mail, signature. The persons concerned by this processing may be: individuals attending the event (speaker), contact persons of catering, transportation, accommodation, travel agencies, advertisers, persons whose signature appears on the minutes.
Purposes and grounds for processing
Personal data belonging to suppliers’ contact persons are collected by the CSDF for the purpose of concluding service procurement contracts and for ensuring effective communication with these suppliers. These purposes are part of the general purpose of implementing CSDF’s activities and projects. The basis of processing falls into two categories:
(I) the legitimate interest of the CSDF, in the case of service providers that are legal persons, authorized natural persons or sole proprietorships.
(II) the execution of service supply contracts, in the case of service providers who are natural persons.
In the case of (i) above, the CSDF has a legitimate interest in collecting the contact information of contact persons at the providers in order to communicate effectively with those providers, and the contact persons are the employees of those providers.
In the case of (ii) above, the CSDF collects the personal data of service providers – natural persons in order to perform the service contracts concluded with them and to communicate effectively with them.
About the transfer of personal data
This personal data between the operator (CSDF) and the authorized persons (third parties) may be transferred outside Romania, depending on the program for which the beneficiary applies. In addition, these personal data may be transferred to the following categories of persons: accounting firm (copies of contracts annexed to the supporting documents of employment and payment), external auditors, including statutory audit, tax authorities and other public authorities in case of potential control by them, as well as to the funders / Responsible Intermediate Bodies / Managing Authorities for the justification of the reimbursement of expenses incurred within the projects implemented by FDSC.
Data retention period
For the situation set out in (i) above, personal data will be retained for as long as the individual whose data is being processed remains the contact person of the respective provider. For the situation referred to in (ii) above, for the duration of the performance of the service contract with the natural person service provider whose personal data have been processed by CSDF.
- Processing of personal data of beneficiaries of Structural and Cohesion Funds (ESF) projects
- Categories of personal data processed
Personal data belonging to the beneficiaries of Structural and Cohesion Funds (ESF) projects that can be collected by the CSDF are: name, surname, address, telephone, e-mail, nationality, CNP, series and number of identity card, copy of ID card, copy of ID card, school certificates, professional profile, function, specialty, schools attended, health status, disabilities, ethnicity, signature, etc. In principle, all types of personal data can be collected from project beneficiaries.
Purposes and grounds for processing
Personal data belonging to project beneficiaries are collected by CSDF, which will process them for the purpose of implementing POSDRU projects, both in the accreditation stage of the training program and for the documentation of the “target group” according to ESF requirements. The basis for processing is represented by: the legitimate interest of the CSDF to verify how the projects are implemented by the NGOs receiving funding and whether the objective is achieved, as well as the legal obligation under the applicable legal provisions on POSDRU programs.
About the transfer of personal data
These personal data, exchanged between the operator (CSDF) and its authorized representatives (third parties) will not be transferred outside Romania. In addition, these personal data may be transferred to the following categories of persons: Responsible Intermediary Bodies, providers of accommodation, meals and transportation services, school principals who are members of the target group, evaluators and/or auditors, CSDF partners in a consortium.
Data retention period
This will be carried out in accordance with the contractual provisions concluded between the FDSC and the competent authorities and taking into account potential control by the authorities in charge.
VII. Processing of personal data of persons who register on CSDF’s websites in order to participate in events organized by CSDF.
Categories of personal data processed
Registration of users on CSDF websites in order to register for participation in events organized by CSDF. Data subjects are: contact persons within the organization/campaign/public institution registering on the website, individuals registering on the website. The personal data that may be processed by the CSDF are: name, surname, function, telephone, e-mail of the contact person, name of the organization/company/public institution on behalf of which the registration on the website is made.
Purposes and grounds for processing
CSDF collects and processes personal data (i) of contact persons within the organization/campaign/public institution and (ii) of individuals when they register on the website in order to access the additional facilities. The purpose of the processing is therefore to provide the additional facilities.
About the transfer of personal data
This personal data between the operator (CSDF) and the authorized persons (third parties) will not be transferred outside Romania. In addition, they may be transferred to the IT company that maintains the site.
Data retention period
The maximum period of retention of personal data is to be determined in accordance with the applicable legal provisions and the specific need of CSDF to retain such personal data.
VIII. Processing of personal data of the final beneficiaries of the projects implemented by CSDF, of the contact persons of the service providers legal entities and of the collaborators natural persons for the purpose of organizing events by CSDF.
Categories of personal data processed
The personal data that will be processed by CSDF may be: name, surname, e-mail address, image, signature, telephone number, medical data (e.g. disabilities of persons), date of birth, personal numeric code, spouse/children’s name, position, name of organization, ID card number, address, place of birth, data contained in CV. The persons concerned by this processing may be: beneficiaries of the projects, the contact person within the service providers, legal entities, collaborators, natural persons.
Purposes and grounds for processing
CSDF collects and processes the personal data of the data subjects specified above for the purpose of organizing events to support the projects it runs. The legitimate interest of CSDF to process the personal data of data subjects in order to organize events to promote its ongoing projects.
About the transfer of personal data
This personal data between the operator (CSDF) and the authorized third parties (third parties) may be transferred outside Romania, depending on the event. In addition, these personal data may be transferred to the following categories of persons: financiers, travel agencies, hotels, airlines, media and advertising agencies, journalists.
Data retention period
The maximum period of retention of personal data is to be determined in accordance with the applicable legal provisions and the specific need of CSDF to retain such personal data.
- Processing of personal data of CSDF employees, beneficiaries of projects implemented by CSDF, supporters of NGOs for the purpose of publishing articles and interviews on websites
- Categories of personal data processed
The website publishes articles, interviews or life stories about employees, beneficiaries or supporters of NGOs. The personal data that may be processed by the CSDF are: name, surname, position, disability, health, education, training. In principle, many categories of personal data may appear in the articles concerning personal or professional life, preferences, experiences, etc.
Purposes and grounds for processing
CSDF collects and processes the personal data of the data subjects specified above for the purpose of publishing articles and interviews about these persons on various websites owned by CSDF.
About the transfer of personal data
These personal data between the operator (CSDF) and the authorized persons (third parties) will not be transferred outside Romania. In addition, these personal data may be transferred to the following categories of persons: the general public reading the article/interview, the IT company maintaining the website.
Data retention period
The maximum period of retention of personal data is to be determined in accordance with the applicable legal provisions and the specific need of CSDF to retain such personal data.
- Processing of personal data of persons completing online questionnaires – representatives of the applicant organization and individuals completing the questionnaire for feedback purposes
- Categories of personal data processed
The personal data that may be processed by CSDF are: name, surname, job, position, nationality, gender, telephone number, e-mail address, profession, professional experience, culinary preferences (if they are vegetarian or have any dietary preferences) etc.
Purposes and grounds for processing
CSDF processes the personal data of the following categories of persons in order to obtain their feedback on the projects/events carried out: i) The representative of the applying organization, ii) Persons working or collaborating with CSDF within the projects, iii) Members/supporters of non-governmental organizations. Individuals generally interested in the various topics addressed by FDSC in its current actions.
About the transfer of personal data
This personal data between the operator (CSDF) and the authorized persons (third parties) may be transferred outside Romania, depending on the program. In addition, these personal data may be transferred to the following categories of persons: the evaluators and/or auditors on the occasion of controls carried out by them, tax authorities and other public authorities in case of a potential control by them, CSDF partners in case a project is being worked on within a consortium.
Data retention period
The maximum period of retention of personal data is to be determined in accordance with the applicable legal provisions and the specific need of CSDF to retain such personal data.
- Processing personal data of persons visiting the CSDF websites for the purpose of ensuring the functionality of the website
- Categories of personal data processed
The personal data collected by CSDF are : IPs from where the site is accessed.
Under certain conditions the name of the contact person (first name, surname, e-mail address) is collected.
The persons concerned by this processing are: visitors to the site.
Purposes and grounds for processing
CSDF uses cookies to process the personal data of people who access CSDF websites in order to ensure the functionality of these websites.
About the transfer of personal data
This personal data between the operator (CSDF) and the authorized persons (third parties) will not be transferred outside Romania. In addition, these personal data may be transferred to the following categories of persons: the evaluators and/or auditors on the occasion of controls carried out by them, tax authorities and other public authorities in case of a potential control by them, CSDF partners in case of working on a project within a consortium, IT and website maintenance companies.
Data retention period
The maximum retention period for personal data is five years.
XII. Processing of personal data of real beneficiaries and representatives of organizations applying for funding, real beneficiaries and representatives of legal entities/authorized natural persons/individual enterprises with which CSDF concludes service provision contracts, in order to fulfill the legal obligations of know-your-customer when establishing business relationships.
Categories of personal data processed
The personal data that may be processed by CSDF are: name, surname, date of birth, nationality, country of residence, photo, etc. Data subjects: final beneficiaries of the projects (individuals) and contact persons within the applying organizations.
Purposes and grounds for processing
The CSDF processes the personal data of the above-mentioned persons in order to go through the Know Your Customer procedure, in accordance with the applicable legal provisions on the prevention and sanctioning of money laundering, as well as for the establishment of measures to prevent and combat terrorist financing. The CSDF is obliged to apply know your customer measures when establishing business relationships, in order to comply with the legal requirements on the prevention and sanctioning of money laundering, as well as for the establishment of measures to prevent and combat terrorist financing. Thus, the CSDF must inquire about the beneficial owner of the legal entity, but also obtain evidence that the natural person representing a particular legal entity is acting legally.
About the transfer of personal data
These personal data between the operator (CSDF) and the authorized persons (third parties), will not be transferred outside Romania, according to the program. In addition, these personal data may be transferred to the competent authorities.
Data retention period
Personal data is kept in accordance with the legal requirements applicable in this situation.
Civil Society Development Foundation assumes the obligation to obtain the consent of the persons who will be subject to the processing of personal data in all situations in which sensitive information will be provided to us. According to the legislation in force, the following personal data are considered sensitive: personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data processed solely for the purpose of identifying a human being, data concerning health, data concerning a person’s sex life or sexual orientation.
Rights regarding the processing of personal data:
(a) Right of access: I have the right to request information from CSDF about the processing of my personal data by CSDF.
(b) Right of rectification: I have the right to request CSDF to rectify my personal data that is incorrect.
(c) Right of erasure: I have the right to request CSDF to erase my personal data in certain situations, such as: the personal data are no longer necessary for the fulfillment of the processing purpose for which they were collected, consent to their processing by CSDF has been withdrawn.
(d) Right to restrict processing: I have the right to request CSDF to restrict processing by CSDF in certain situations, such as where I challenge the accuracy of personal data processed by CSDF, the processing of personal data is not carried out in accordance with the law.
(e) The right to object: I have the right to object at any time, on compelling legitimate grounds relating to my particular situation, to the processing of data relating to me, except where otherwise provided by law
(f) The right of portability: I have the right to request CSDF to transmit my personal data processed by CSDF to me or to another entity that is to process my personal data.
The FDSC can be contacted in relation to the above by e-mail at bianca.oprea[at]fdsc.ro or by phone at 021.31.00.181. You may also address any complaints and complaints to the National Supervisory Authority for Personal Data Processing.
