ERA Shuttle Project GDPR Policy

AI-Powered Interview Consent (optional)

Participation in an AI-powered interview is not mandatory and will not impact your eligibility for a secondment. It is meant to be a supportive tool towards our goals of supporting you to create your individual career development plans. By consenting, you agree to:

• The use of Large Language Models (LLM) tools for the purpose of supporting the individual career development plans.
• Allowing us to store any data created during the usage of the LLM mentioned in point one. Our server in located in Germany and therefore follows GDPR standards.

For questions or to exercise your data rights related to AI usage, contact the DPO of S&M at [email protected] or [email protected].

We are attentively following the updates and abiding by the EU AI Act when using AI in our ERA Shuttle Project.

Information on processing of personal data with expanded details:

1. The administrators of personal data under the ERA SHUTTLE project are:
   
   1. University of Malta, Msida MSD 2080, Malta
   2. University of Split, Ruđera Boškovića 31, 21000 Split, Croatia 
   3. University of Gdansk, 8 Jana Bazynskiego St., 80-309 Gdansk, Poland

For further inquiries or to exercise your rights, you may also request the updated list of data processors at the data controller’s office or on their website www.acrosslimits.com.

2. The Data Protection Officers (DPOs) at each of the co-administering institutions may be contacted on matters related to the processing of personal data:

1. 1. University of Malta:  [email protected]
   2. University of Split: [email protected]
   3. University of Gdansk: [email protected]
   4. AcrossLimits is responsible for the online recruitment application portal and storage
2. 1. Data Protection Officer (DPO)
      Name: Emanuele Pristerà
      Designation: Head – IT and Digital Media Development department
      Email: [email protected]
3. 1. Data Controller
      The data controller is AcrossLimits Ltd (Malta).
      Registered Address: 2nd Floor, Tower Business Centre, Tower Street, Swatar, Birkirkara, BKR 4013, Malta
      Legal Representative: Angele Giuliano
      Email: [email protected]

3. Processing of personal data is carried out on the basis of:

1. 1. Consent of participants (Article 6(1)(a) of the GDPR).
   2. Implementation of the project grant agreement (Article 6(1)(b) of the GDPR).
   3. Fulfilment of the administrator’s legal obligation (Article 6(1)(c) GDPR).
   4. Legally legitimate interests pursued by the administrator (Article 6(1)(f) GDPR).

4. Personal information may be shared with:

1. 1. Entities authorized to access the data under applicable laws.
   2. Providers of services that ensure proper execution of tasks by Data Controllers, in particular IT service providers.
   3. The European Commission as part of inspections and audits.
   4. Within the framework of secondment for the implementation of project activities, personal data of participants may be transferred to other partner organizations of the ERA SHUTTLE project for the necessary implementation of the project activities in accordance with the GDPR provisions. The transfer of data shall be carried out in accordance with the provisions of the European GDPR and shall ensure an adequate level of personal data protection.

5. Personal data will be kept for the duration of the project and for a minimum period of five years counted from January 1 following the date of completion of the project, as required by the funding body and applicable law.

6. Data subjects have the right to:

1. 1. Access to their personal data.
   2. Correction of incorrect data.
   3. Deletion of data (right to be forgotten).
   4. Restriction of data processing.
   5. Transfer of data.
   6. Object to data processing.
   7. Withdraw consent to data processing in connection with participation in an interview with an LLM-based bot, without affecting the compatibility of data processing prior to withdrawal of consent.

7. Providing personal data is voluntary, but necessary for the proper submission and processing of the application. The processing of data by AI  (LLM) in the career development plans is voluntary and does not affect the ability to properly submit and process the application.

8. Data subjects have the right to lodge a complaint if you consider that the processing of your personal data violates the provisions of the GDPR to the supervisory authority in the country where you reside, work or where the alleged violation occurred:

1. 1. Malta: Office of the Information and Data Protection Commissioner (IDPC); Address: Level 2, Airways House, High Street, Sliema SLM 1549, Malta.
   2. Croatia: Agencija za zaštitu osobnih podataka (AZOP) Address: Selska cesta 136, 10000 Zagreb, Croatia
   3. Poland: Urząd Ochrony Danych Osobowych (UODO) Address: 2 Stawki Street, 00-193 Warsaw, Poland.
   4. Germany: Federal Commissioner for Data Protection and Freedom of Information (BfDI); Address: Graurheindorfer Str. 153, 53117 Bonn, Germany.
   5. To list other partners country responsible body

9. Administrators inform that they use hierarchical databases (Active Directory) as part of their operations and to this extent may store personal data in the cloud, which may result in the transfer of personal data to a recipient in a third country, but the transfer of such data shall be carried out in accordance with the principles set forth in Article 49 of the GDPR or based on standard contractual clauses. Personal data will not be processed by automated means, including profiling as referred to in Article 22 (1) and (4) of the GDPR.