Date: October 2020
ISTC is an intergovernmental organisation funded by the European Union, Japan and the United States governments and headquartered in Kazakhstan with the aim to advance global peace and prosperity through cooperative Chemical, Biological, Radiological, and Nuclear (CBRN) risk mitigation by supporting civilian science and technology partnerships and collaboration that address global security threats and advance non-proliferation.
International Science and Technology Center in Kazakhstan (ISTC) as controllers of personal data is dedicated to protecting the confidentiality and privacy of information entrusted to it. As part of this fundamental obligation, ISTC is committed to the appropriate protection and use of personal data” that has been collected. Personal data is any information which can be used directly or indirectly to identify a person.
Generally, our intent is to collect only the personal data that is provided voluntarily by individuals who are participating in ISTC actions so that we can contact those individuals and they can participate in the specific actions or offer information about employment opportunities. Please review this privacy policy ("Privacy Policy") to learn more about how we collect, use, share and protect the personal information that we have obtained.
1. Collection and use of personal information
1.1. What information we collect
1.2 The legal grounds we have to use your personal information
ISTC generally collects only the personal information necessary to fulfil your request. Where additional, optional information is sought, you will be notified of this at the point of collection.
The law allows us to process personal information, so long as we have a ground under the law to do so. It also requires us to tell you what those grounds are. As a result, when we process your personal information, we will rely on one of the following processing conditions:
• Performance of a contract: this is when the processing of your personal information is necessary in order to perform our obligations under a contract;
• Legal obligation: this is when we are required to process your personal information in order to comply with a legal obligation, such as keeping records for tax purposes or providing information to a public body or law enforcement agency;
• Legitimate interests: we will process information about you where it is in our legitimate interest in implementing ISTC’s activities to do so in order to further those aims, so long as it doesn’t outweigh your interests; or
• Your consent: in some cases, we will ask you for specific permission to process some of your personal information, and we will only process your personal information in this way if you agree to us doing so. You may withdraw your consent at any time by contacting ISTC at privacy@istc.int.
Examples of the ‘legitimate interests’ referred to above are:
• To offer information and/or services to individuals who visit our website or offer information about employment opportunities.
• To prevent fraud or criminal activity and to safeguard our IT systems.
• To customize individual’s online experience and improve the performance usability and effectiveness of the ISTC website.
• To meet our corporate and social responsibility obligations.
ISTC only collects personal data to perform ISTC’s actions we do not collect special categories of data, such as diversity related information (including data about racial and ethnic origin, political opinions, religious beliefs and other beliefs of a similar nature, trade union membership and data about sexual life and sexual orientation), or health data and data about alleged or proven criminal offences.
1.3 Automatic collection of personal information
In some instances, ISTC and its service providers uses cookies, web beacons and other technologies to automatically collect certain types of information when you visit us online, as well as through emails that we may exchange. The collection of this information allows us to customize your online experience, improve the performance, usability and effectiveness of ISTC's online presence.
1.3.1 IP addresses
An IP address is a number assigned to your computer whenever you access the internet. It allows computers and servers to recognise and communicate with one another. IP addresses from which visitors appear to originate may be recorded for IT security and system diagnostic purposes. This information may also be used in aggregate form to conduct web site trend and performance analysis.
1.3.3 Google Analytics
ISTC uses Google Analytics. More information about how Google Analytics is used by ISTC can be found here: http://www.google.com/analytics/learn/privacy.html
To provide website visitors with more choice on how their data is collected by Google Analytics, Google have developed the Google Analytics Opt-out Browser Add-on. The add-on communicates with the Google Analytics JavaScript (ga.js) to indicate that information about the website visit should not be sent to Google Analytics. The Google Analytics Opt-out Browser Add-on does not prevent information from being sent to the website itself or to other web analytics services.
1.4 Social media widgets and applications
ISTC web sites may include functionality to enable sharing via third party social media applications, such as the Facebook Like button and Twitter widget. These social media applications will collect and use information regarding your use of ISTC web sites (see details on 'Social Sharing' cookies above). Any personal information that you provide via such social media applications will often be collected and used by other members of that social media application and such interactions are governed by the privacy policies of the companies that provide the application. We do not have control over, or responsibility for, those companies or their use of your information.
In addition, ISTC web sites may host blogs, forums, crowd-sourcing and other applications or services (collectively "social media features"). The purpose of social media features is to facilitate the sharing of knowledge and content. Any personal information that you provide on any ISTC social media feature will typically be shared with other users of that social media feature (unless otherwise stated at the point of collection), over whom we often have limited or no control.
1.5 Children
ISTC understands the importance of protecting children's privacy, especially in an online environment. In particular, our sites are not intentionally designed for or directed at children under the age of 13. It is our policy never to knowingly collect or maintain information about anyone under the age of 13, except as part of an engagement to provide professional services.
1.6 Direct marketing
ISTC does not conduct direct marketing however we may use your personal data to invite you to participate in ISTC activities such as: Seminars, conferences and other ISTC organised events
2. Sharing and transfer of personal data
We do not share personal data with third parties, except as necessary for our legitimate professional and business needs, to carry out your requests, and/or as required or permitted by law or professional standards.
ISTC will not transfer the personal data you provide to any third parties for their own direct marketing use.
3. Choices
In general, you are not required to submit any personal information to ISTC, but we will require you to provide certain personal information in order for you to participate in ISTC activities and events. ISTC will also ask for your permission for certain uses of your personal information, and you can agree to or decline those uses.
The ISTC use mass communications such as email newsletters, but your personal information will not be disclosed in connection with such activities.
4. Your rights
If ISTC processes personal information about you, you have the following rights:
• Ask questions: If you have questions or comments about our administration of your personal information, please contact us at e-mail privacy@istc.int.
• Confidentiality of electronic communications: The information contained in electronic mail (email) transmission (including attachments), is intended by the ISTC for the use of the named individual or entity to which it is addressed and may contain information that is privileged or otherwise confidential. It is not intended for transmission to, or receipt by, any individual or entity other than the named addressee except as otherwise expressly permitted in email transmission.
• Access and correction: you have the right to access to that data. If we agree that we are obliged to provide personal information to you, we will provide it to you free of charge. Before providing personal information to you, we may ask for proof of identity and sufficient information about your interactions with us that we can locate your personal information. If the information we hold about you is incorrect, you are entitled to ask us to correct any inaccuracies in the personal information.
• Object to processing: you have the right to object to us processing your personal information if we are not entitled to use it any more
• Other Rights: in addition, you may have rights to have your information deleted if we are keeping it too long, have its processing restricted in certain circumstances and/or to obtain copies of information we hold about you in electronic form.
You can make a request or exercise these rights by contacting ISTC at privacy@istc.int and we will make all reasonable and practical efforts to comply with your request, so long as it is consistent with applicable law and professional standards.
5. Data sources
Personal data should be collected from the data subject and processed as documented in the “ISTC Privacy Policy”.
Personal data could be collected from other sources when the following apply:
• The nature of the business purpose necessitates collection of the personal data from other persons or bodies (e.g. job references);
• The collection must be carried out under emergency circumstances in order to protect the vital interests of the data subject or to prevent serious loss or injury to another person.
If personal data is collected from someone other than the data subject, the data subject must be informed of the collection unless one of the following apply:
• The data subject has received the required information by other means;
• The information must remain confidential due to a professional secrecy obligation;
• A national law expressly provides for the collection, processing or transfer of the personal data.
Where it has been determined that notification to a data subject is required, notification should occur promptly, but in no case later than:
• One calendar month from the first collection or recording of the personal data;
• At the time of first communication if used for communication with the data subject;
• At the time of disclosure if disclosed to another recipient.
6. Data security and integrity
ISTC has reasonable security policies and procedures in place to protect personal information from unauthorized loss, misuse, alteration, or destruction. Despite ISTC's best efforts, however, security cannot be absolutely guaranteed against all threats. To the best of our ability, access to your personal information is limited to those who have a need to know. Those individuals who have access to the data are required to maintain the confidentiality of such information.
We also make reasonable efforts to retain personal information only for so long
i) as the information is necessary to comply with an individual's request,
ii) as necessary to comply with legal, regulatory, internal business or policy requirements, or
iii) until that person asks that the information be deleted.
The period for which data is retained will depend on the specific nature and circumstances under which the information was collected. You are entitled to request information about specific storage period regarding your data by contacting ISTC at e-mail privacy@istc.int.
ISTC may modify this Privacy Policy from time to time to reflect our current privacy practices. When we make changes to this policy, we will revise the "updated" date at the top of this page.
8. Policy questions and enforcement
ISTC is committed to protecting the online privacy of your personal information. If you have questions or comments about our administration of your personally identifiable information, please contact us at privacy@istc.int. You may also use this address to communicate any concerns you may have regarding compliance with our Privacy Policy.
We will acknowledge your email within 20 days and seek to resolve your concern within one month of receipt. Where the concern is complex or we have a large volume of concerns, we will notify you that the concern will take longer than one month to resolve, and we will seek to resolve your concern within three months of the concern being first raised. We may accept your concern (and in that case implement one of the measures set out in the ‘Your Rights’ section above), or we may reject your concern on legitimate grounds.
Data Transfers to Third Parties
We do not share personal information with third parties, except as necessary for our legitimate interests - legitimate professional and business needs, to carry out your requests, and/or as required or permitted by law or professional standards. This may include:
