What is the privacy policy about?
Data protection is a matter of trust, and your trust is important to us. This is why we have published this privacy policy, to inform you how and for what purpose we collect, process and use your personal data.
Among other things, this privacy policy will tell you:
- what personal data we collect and process;
- the purposes for which we use your personal data;
- who has access to your personal data;
- what benefits our data processing has for you;
- for how long we process your personal data;
- what rights you have in relation to your personal data; and
- how you can contact us.
Who is responsible for data processing?
The University of Applied Sciences of the Grisons, Pulvermühlestrasse 57, 7000 Chur, Switzerland (“UAS Grisons”, “we” or “us”), is responsible for data processing in accordance with this privacy policy.
Terms
- Personal data is an umbrella term for all information that refers to a specific or identifiable natural person.
- A data subject is a person whose personal data is processed.
- Processing includes any handling of personal data, regardless of the means and procedures used, such as the retrieval, comparison, adaptation, archiving, storage, reading, disclosure, procurement, recording, collection, deletion, publication, ordering, organisation, saving, modification, dissemination, linking, destruction and use of personal data.
- Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person. In particular, this involves analysing or predicting aspects relating to the work performance, economic situation, health, personal preferences, interests, reliability, behaviour, location or change of location of this natural person.
- Cookies are files that contain certain technical data and are stored and saved on a computer system via an Internet browser. The data subject can prevent cookies being stored by our website at any time by configuring their Internet browser accordingly and thus permanently object to the setting of cookies. Furthermore, cookies that have already been set can be deleted at any time via an Internet browser or other software programs.
- The technical data includes, among other things:
- the IP address of your device and other device IDs (e.g. MAC address);
- identification numbers assigned to your device by cookies and similar technologies (e.g. pixel tags);
- information about your device and its configuration, e.g. operating system or language settings;
- details of the browser you are using to access the website and its configuration;
- information about your movements and actions on our websites and in our apps;
- information about your internet provider;
- your approximate location and the time of use;
- system-side records of instances of access and other processes (log data).
- peripheral telecommunications data
What sources and data do we use?
We process data that is generated as part of the use of our websites, apps or Wi-Fi networks (technical data), that you provide to us (e.g. as part of newsletter registrations, registrations for events, filling out web forms or other orders) or that is generated as part of the contractual process. This can be in particular in connection with studies, further education, research or services.
We collect your personal data in particular when you contact us, for example via our websites, as an interested party, customer, applicant, person submitting a request, etc. We process personal data that we receive from our customers as part of our business relationship. In addition, we process – to the extent necessary for the provision of our services – personal data that we legitimately obtain from publicly accessible sources.
Relevant personal data are personal details (title/gender, name, address and other contact details, date and place of birth, nationality) and legitimisation data (e.g. ID card data). In addition, order data, data from the fulfilment of our contractual obligations, advertising and sales data, documentation data and other data comparable with the aforementioned categories may also be processed.
We may listen to or record telephone or video conferences for training, evidence and quality assurance purposes. In such cases, we will notify you separately (e.g. by means of a display or announcement) and you are free to inform us if you do not wish to be recorded or to terminate the communication (if you simply do not want your image to be recorded, please switch off your camera). We may also process personal data for organising, implementing and following up on events, in particular participant lists and the content of presentations and discussions, as well as image and audio recordings made during these events.
If you use our website for purely informational purposes, i.e. if you do not fill out any web forms and do not register for an event or otherwise provide us with information, we collect technical data that your browser transmits. This data is not merged with other data sources. The sole purpose of this data collection is to optimise and improve the user-friendliness of our website. We reserve the right to check this data if we become aware of concrete evidence of unlawful use.
You may be able to log in to individual online services using the login of a third-party provider (e.g. Switch edu-ID). In this case, we receive access to certain data stored by the provider in question, such as your name and e-mail address. Information on this can be found in the privacy policy of the provider concerned.
How do we process particularly sensitive personal data?
Certain types of personal data are considered “particularly sensitive” under data protection law, e.g. information on health and biometric characteristics. Depending on the circumstances, personal data may also include such particularly sensitive personal data. However, we generally only process particularly sensitive personal data if this is necessary for the provision of a service, if you have provided us with this data yourself or if you have consented to the processing. We may also process particularly sensitive personal data if this is necessary to uphold rights or comply with domestic or foreign legal requirements, if the data in question has clearly been publicly disclosed by the data subject or if the applicable law permits its processing.
On what legal basis and for what purpose do we process your data (purpose of processing)?
As an institution under public law, we process personal data on the legal basis of the Cantonal Act on Universities and Research (GHF, BR 427.200) in accordance with the provisions of the Cantonal Data Protection Act (KDSG, BR 171.100) of the Canton of Graubünden, the Swiss Federal Act on Data Protection (FADP, SR 235.1) and the European General Data Protection Regulation (GDPR, Regulation 2016/679), insofar as the corresponding regulations are applicable. As the GDPR requires us to list these individually, the legal bases for our processing, insofar as the GDPR applies, are listed below. When processing personal data in accordance with the KDSG or FADP, we rely on the comparable legal bases in these laws.
For the fulfilment of contractual obligations (Art. 6 (1) b GDPR)
Data is processed for the provision of services of the UAS Grisons in the context of the fulfilment of our contracts (e.g. in the areas of education and training and in connection with our services) with our customers or for the implementation of pre-contractual measures that are carried out on request. The purposes of data processing depend primarily on the specific service and may include activities such as training or consultations. The contractual documents and terms and conditions may contain further details on the purposes of data processing.
As part of the balancing of interests (Art. 6 (1) f GDPR)
Where necessary, we process your data beyond the actual fulfilment of the contract to protect our legitimate interests or those of third parties. Examples:
- advertising or market and opinion research, unless you have objected to the use of your data;
- assertion of legal claims and defence in legal disputes;
- newsletters, event registrations and orders (if the data subject can be expected to send them);
- ensuring IT security and IT operations;
- analysing the internet traffic on our websites, improving the functionality of our websites;
- prevention and investigation of criminal offences;
- measures for business management and further development of services and products.
This also includes the protection of other legitimate interests, which cannot be listed exhaustively.
On the basis of your consent (Art. 6 (1) (a) GDPR)
If you have given us your consent to process personal data for specific purposes (e.g. disclosure of data, analysis of personal data for research and marketing purposes; newsletters, unless there is a legal basis for this based on Art. 6 (1) (b) GDPR), the lawfulness of this processing is based on your consent. Any consent given can be revoked at any time. This also applies to the revocation of declarations of consent given to us before the GDPR came into force, i.e. before 25 May 2018. Revocation of consent does not affect the lawfulness of the data processed up to the time of revocation.
On the basis of legal requirements (Art. 6 (1) (c) GDPR) or in the public interest (Art. 6 (1) (e) GDPR)
In addition to the provisions of the Federal Act on the Funding and Coordination of the Higher Education Sector (HEdA) and the Act on Universities and Research (GHF), the UAS Grisons is also subject to the other statutory requirements of Swiss law. This means that personal data can also be processed if this is required by law or if the processing is in the public interest. The basis for this, in particular for studies and continuing education, is Art. 24 HEdA and Art. 2, 9 GHF.
Who receives your data?
Within the UAS Grisons, those departments that need your data to fulfil our contractual and legal obligations will have access to it. Service providers employed by us may also receive data for these purposes. These include companies in the categories of personnel consulting, IT services, logistics, printing services, telecommunications, consulting and advisory services as well as sales and marketing.
All these categories of recipients may in turn involve third parties, meaning that your data may also become accessible to them. We can restrict processing by certain third parties (e.g. IT providers), but not by others (such as authorities and banks).
- Other recipients of personal data may include, for example
- Public bodies and institutions (e.g. authorities and courts) in the event of a legal or official obligation.
- Facilities within the UAS Grisons for risk management based on legal or official obligations.
- Those bodies for which you have given us your consent to transfer data or for which you have released us from the duty of confidentiality in accordance with the agreement or consent.
We enable certain third parties to collect personal data from you on our website and at our events, including on their own responsibility (e.g. media photographers, providers of tools that we have integrated into our website (see section 13.4), etc.). Insofar as we are not decisively involved in this data collection, the responsibility for this lies solely with these third parties. If you have any concerns and wish to assert your data protection rights, please contact these third parties directly.
Is data transferred to a third country?
We generally process personal data in Switzerland and the European Economic Area (EEA). However, it is possible for personal data to be exported or transferred to other countries, in particular in order to process it or have it processed there, provided that
- this is required by law, or
- the third countries are on the list of countries with adequate data protection, or
- we have provided suitable guarantees through appropriate mechanisms (e.g. contracts), or
- you have given us your consent.
Is your data secure?
We take appropriate technical and organisational measures to protect your data from unauthorised access and misuse.
Our employees and the service providers we commission are pledged by us to uphold data security and comply with the data protection regulations. Furthermore, they are only granted access to personal data to the extent necessary.
For how long will your data be processed?
We generally process your data for as long as required by our purposes for the processing and by the statutory retention periods, in particular for documentation and evidence purposes, or for as long as storage is necessary from a technical standpoint (e.g. for backups). Provided there are no legal, contractual or technical reasons to the contrary, we generally delete or anonymise your data after the retention period has expired as part of our usual processes.
As an institution under public law, we are obliged under the Act on Record Keeping and Archiving (GAA, BR 490.200) of the Canton of Graubünden to offer all documents to the State Archives after the retention period has expired. The documents managed by the State Archives are subject to a protection period of 30 years, or 50 years in the case of particularly sensitive personal data and are only accessible after this period has expired.
What rights do you have in connection with the processing of your personal data?
You have the right to object to data processing, especially if we process your personal data on the basis of a legitimate interest and the other applicable requirements are met. You can also object to data processing in connection with direct marketing (e.g. advertising e-mails) at any time. This also applies to profiling, insofar as this is associated with such direct marketing.
As long as the applicable requirements are met and no statutory exceptions apply, you also have the following rights:
- the right to request information about your personal data stored by us;
- the right to have incorrect or incomplete personal data rectified;
- the right to request the erasure or anonymisation of your personal data;
- the right to request the restriction of the processing of your personal data;
- the right to receive certain personal data in a structured, commonly used and machine-readable format;
- the right to revoke consent with effect for the future, insofar as processing is based on consent. Processing that took place before the revocation is not affected by this.
Please note that these rights may be restricted or excluded in individual cases, e.g. if there are doubts about your identity or if this is necessary to protect other persons, to safeguard legitimate interests or to comply with legal obligations. In any case, the processing of your claim according to your rights will only begin after a successful identity check.
If the GDPR is applicable, the following applies: Every data subject has the right of access under Art. 15 GDPR, the right to rectification under Art. 16 GDPR, the right to erasure under Art. 17 GDPR, the right to restriction of processing under Art. 18 GDPR, the right to object under Art. 21 GDPR and the right to data portability under Art. 20 GDPR. In addition, you have the right to lodge a complaint with a competent data protection supervisory authority (Art. 77 GDPR).
Please submit any requests to exercise your rights in writing to the contact indicated under point 13.
You are also free to lodge a complaint with a competent supervisory authority if you have concerns as to whether the processing of your personal data complies with the law.
- Competent supervisory authorities in Switzerland:
Do you have an obligation to provide data?
As part of our business relationship, you must provide the personal data that is necessary for the establishment and implementation of a business relationship and the fulfilment of the associated contractual obligations or that we are legally obliged to collect. Without this data, we will generally not be able to conclude or fulfil a contract with you.
Tracking, profiling, IT system logs and external content
Generally speaking, the technical data and cookies collected by us do not contain any personal data. However, personal data about you that is stored by us or by third-party providers commissioned by us (e.g. if you have a user account with us or these providers) may be linked to the technical data or to the information stored in and obtained from cookies and thus possibly to your person.
Tracking
We use tools and services from third-party providers (which may in turn use cookies) on our website, in particular to improve the functionality or content of our website, to compile statistics and to place adverts.
Tracking can be prevented by applying the “do not track” setting found in commonly used Internet browsers. This setting also causes the “do not track” tag to be sent in the browser request in the header block, so that the visitor’s actions are not analysed. We use the following in particular:
- Adform: Adform A/S (Denmark)
- Facebook, Instagram: Meta Platforms Ireland Limited (Ireland)
- Fusedeck: Capture Media AG (Switzerland)
- Google Tag Manager, Google Analytics, Google Optimize, DoubleClick Digital Marketing: Google Ireland Limited (Ireland)
- LinkedIn: LinkedIn Ireland Unlimited Company (Ireland)
- Pinterest: Pinterest Inc (USA)
- Reddit: Reddit Netherlands B.V. (Netherlands)
- Snapchat: Snap Switzerland GmbH (Switzerland)
- TikTok: TikTok Technology Limited (Ireland)
IT system logs
Every time you use the websites, apps or Wi-Fi networks, e.g. when accessing websites and sending e-mails, data is automatically transmitted, some of which could be classified as personal data, and is stored by us in so-called system logs. The system logs are stored by the UAS Grisons to identify faults and for security reasons. If the data is no longer required for the fulfilment of operational or legal obligations, it will be deleted.
External content
External content is displayed or linked on the web pages. The IP address is transmitted, and the content providers can set cookies etc. If the visitor to the website is logged into the network of the respective third-party provider at the same time, the visit to the website may be associated with this user account, depending on the provider. The identity and contact details of the respective provider can be found in the privacy policy. The UAS Grisons has a legitimate interest in integrating this external content or linking to it, but has no influence on the way in which data is transmitted.
We use the following in particular:
- Aiaibot: swiss moonshot AG (Switzerland)
- Flickr: Flickr, Inc (USA)
- Microsoft Captcha: Microsoft Ireland Operations Limited (Ireland)
- Vimeo: Vimeo.com Inc (USA)
- YouTube, Google Maps, Google Fonts: Provider: Google Ireland Limited (Ireland)
Content on third-party platforms
We operate pages and other online presences on social networks and other platforms operated by third parties, and we process data from you in this context. We receive personal data from you and from the platforms (e.g. statistics), for instance when you communicate with us or comment on our content. We have the right, but not the obligation, to review content before or after its publication on our online presences, to delete content without prior notice and, if necessary, to report it to the respective platform provider.
The platform providers themselves can analyse your use and process this data together with other data they have about you. This applies in particular if you are already registered with these platforms. This data is also processed by the platform providers for their own purposes such as marketing and market research as well as for the administration of their platforms, and in this respect, they act as their own data controllers.
For further information on processing by the platform providers, please refer to the privacy policies of the respective platforms.
We only receive an anonymised evaluation of the usage data from these platform operators. Personal user profiles are not created. The anonymised usage statistics help us to better tailor our offers to the needs and interests of our prospective customers.
In the event that the platform operators we use have their registered office outside Switzerland, you will receive information about any disclosure of data abroad by us under section 8.
If you access their offers directly, e.g. by visiting our online presence on social media, you yourself transmit your personal data abroad, and not us.
We currently use the following platforms. The identity and contact details of the respective platform operator can be found in the respective privacy policy:
- Facebook and Instagram: Provider: Meta Platforms Ireland Limited (Ireland)
- Flickr: Flickr, Inc (USA)
- LinkedIn: Provider: LinkedIn Ireland Unlimited Company (Ireland)
- Pinterest: Provider: Pinterest Inc (USA)
- Reddit: Provider: Reddit Netherlands B.V. (Netherlands)
- Snapchat: Provider: Snap Switzerland GmbH (Switzerland)
- Soundcloud: SoundCloud Global Limited & Co. KG (Germany)
- TikTok: Provider: TikTok Technology Limited (Ireland)
- Vimeo: Vimeo.com Inc (USA)
- X: Provider: Twitter International Unlimited Company (Ireland)
- Xing: Provider: New Work XING AG (Switzerland)
- YouTube: Provider: Google Ireland Limited (Ireland)
Audio- und Videokonferenzen
We use special audio and video conferencing services to communicate online. These services enable us, for example, to hold virtual meetings or organise online courses and webinars. Such meetings, courses or webinars may be recorded for teaching, training or evidence purposes. Before we start recording, we will obtain your consent. The legal texts of the individual services also apply to participation in audio and video conferences. These include, for example, privacy policies and terms of use. We use the following in particular:
- Webex: Provider: Cisco Systems Inc. (USA)
- Teams: Provider: Microsoft Ireland Operations Limited (Ireland)
- Zoom: Provider: Zoom Video Communications Inc. (USA)
Moodle
The following data protection information provides an overview of the collection and processing of your data in the Learning Management System (https://moodle.fhgr.ch) of the UAS Grisons (hereinafter referred to as “Moodle”). Moodle is an open-source learning management system (LMS) and is used at the UAS Grisons as a central learning platform. The courses serve as an information and learning resource for students, and Moodle is also used for performance assessments. This data protection information is aimed at all users of Moodle, in particular students and teachers.
Processing for the fulfilment of tasks as a university with cantonal sponsorship
Data is processed by the UAS Grisons in order to fulfil the tasks that are legally assigned to the universities with cantonal sponsorship in accordance with Art. 9 of the Act on Universities and Research (GHF). The performance mandate of the UAS Grisons includes the provision of teaching, continuing education, research and services (Art. 2 GHF).
What sources and data do we use?
We process data that you actively submit yourself, such as forum posts, wiki contributions, completed tasks and exam answers or additions to your profile. We also process data relating to the evaluation of tests, assignments and performance records, which are either automatically generated or actively entered by the course supervisor. We also record which courses you use and what you do in these courses and when (e.g. which pages you have visited). Master data such as your name and e-mail address will then be processed. These can originate from other internal systems as well as from external services such as Switch edu-ID. Every time Moodle is accessed, this is recorded in log files. The log includes technical data such as IP address, information on the browser type, date and time of access.
Why do we process your data?
The data is processed in order to provide the e-learning programmes of the UAS Grisons in the areas of teaching and continuing education and to keep university operations running. This enables mutual interaction in various activities such as chats, forums, surveys or tests.
Your data will also be processed to authenticate and authorise you to use Moodle and to make the settings you have defined in Moodle available again in the same form next time you log in.
The log files are stored for statistical purposes, to ensure provision of the service, to analyse attacks and to ensure technical stability. On the other hand, log files can be accessed as part of examinations and performance records in order to check for instances of dishonesty.
Moodle has a learning analytics function. The aim of this function is to make predictions about the learning success of individual users based on past usage data and current usage behaviour and to make diagnoses and recommendations. This function is currently only used at the UAS Grisons in selected projects for internal research and development purposes.
Stellenbewerbungsplattform
The following data protection information provides an overview of the collection and processing of your data on the application platform (https://jobs.fhgr.ch/) of the UAS Grisons. The application platform is based on a solution from Abacus Umantis AG (Switzerland) and is used at the UAS Grisons as a central application platform. The data is stored and processed on the systems of Abacus Umantis AG. The legal texts of Abacus Umantis AG also apply to the use of the application platform. These include, for example, privacy policies and terms of use. This data protection information is aimed at all users of the application platform.
Processing for the fulfilment of tasks as a university with cantonal sponsorship
Personal data is processed by the UAS Grisons in order to fulfil the tasks that are legally assigned to the universities with cantonal sponsorship in accordance with Art. 9 of the Act on Universities and Research (GHF).
What sources and data do we use?
As part of your application, we process the following personal data that you submit to us:
- Title/gender
- Surname, first name
- Contact details (e-mail address, telephone number, address)
- Date of birth
- Photo
- Audio and video (see paragraph 14)
- Qualifications and professional experience
- CV, cover letter and other application documents
- References and certificates
This data will only be stored, processed and forwarded internally in connection with your application. The data is only accessible to Human Resources employees and the persons involved in the selection process.
Why do we process your data?
Your personal data is processed as part of the application process and/or as part of the conclusion of a mandate contract, cooperation agreement or employment contract. The contractual documents and terms and conditions may contain further details on the purposes of data processing. The data can be processed for statistical purposes (e.g. reporting). It is not possible to draw conclusions about individual persons from this.
Duration of storage
Your personal data will only be stored for as long as is necessary for the purposes for which it was collected or for the statutory retention periods. After completion of the application process, your data (profile and application documents) will be deleted after 3 months at the latest, unless you have expressly agreed to a longer storage period, or a contract has been concluded. In this case, your application documents will be transferred to the personnel dossier. If you have several ongoing applications to the UAS Grisons, your profile will only be automatically deleted 3 months after the most recent application. You will not be notified about the deletion of the data.
If you have agreed to a longer storage period, we will assign your application to a candidate pool. In this case you will receive a message for your information. If you do not agree to this or are no longer interested, you can delete your data (profile and/or application documents) yourself at any time or change your decision in your application profile. If your application is assigned to a candidate pool, the data will be stored for 24 months and then deleted.
How can you contact us?
If you have any questions about this privacy policy or the processing of your personal data, you can contact us at the following address.
UAS Grisons
Martin Berger
Data Protection Officer
Pulvermühlestrasse 57
7000 Chur, Switzerland
datenschutz@clutterfhgr.ch
Changes to this privacy policy
This privacy policy is not part of a contract with you. We can amend this privacy policy at any time. The version published on this website is the current version. We reserve the right to actively inform persons whose contact details are registered with us in the event of significant changes. The version of the privacy policy that is valid at the start of the relevant data processing applies to said processing.