General

The Personal Data Processing Policy (hereinafter referred to as the Policy) was developed in accordance with the Federal Law of July 27, 2006. № 152-FZ "On personal data" (hereinafter - FZ-152).

This Policy defines the procedure for processing personal data and measures to ensure the security of personal data in the Autonomous non-profit organization for the promotion of scientific and educational activities "Noosphere" (hereinafter referred to as the Operator) in order to protect the rights of the user of the service when processing personal data.

The Policy uses the following basic concepts:

• automated processing of personal data - processing of personal data using computer technology;
• blocking of personal data - temporary termination of the processing of personal data (unless the processing is necessary to clarify personal data);
• information system of personal data - a set of personal data contained in databases, and providing their processing of information technologies and technical means;
• depersonalization of personal data - actions, as a result of which it is impossible to determine, without the use of additional information, the belonging of personal data to a specific subject of personal data;
• processing of personal data - any action (operation) or a set of actions (operations) performed using automation tools or without using such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (update, change) , extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data;
• operator - a state body, municipal body, legal entity or individual, independently or jointly with other persons organizing and (or) processing personal data, as well as determining the purposes of processing personal data, the composition of personal data to be processed, actions (operations ) committed with personal data;
• personal data - any information relating directly or indirectly to a specific or identifiable natural person (subject of personal data);
• provision of personal data - actions aimed at disclosing personal data to a certain person or a certain circle of persons;
• dissemination of personal data - actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or at acquaintance with the personal data of an unlimited number of persons, including the disclosure of personal data in the media, posting in information and telecommunication networks or providing access to personal data in any other way;
• cross-border transfer of personal data - transfer of personal data to the territory of a foreign state to a foreign state authority, a foreign natural or foreign legal entity;
• destruction of personal data - actions as a result of which it is impossible to restore the content of personal data in the personal data information system and (or) as a result of which tangible carriers of personal data are destroyed.

The operator is obliged to publish or otherwise provide unrestricted access to this Policy for the processing of personal data in accordance with Part 2, Art. 18.1. FZ-152.

Principles and conditions for the processing of personal data

Principles of Personal Data Processing

The processing of personal data by the Operator is carried out on the basis of the following principles:

• legality and fair basis;
• limiting the processing of personal data to achieve specific, predetermined and legitimate goals;
• preventing the processing of personal data incompatible with the purposes of collecting personal data;
• preventing the merging of databases containing personal data, the processing of which is carried out for purposes incompatible with each other;
• processing only those personal data that meet the purposes of their processing;
• compliance of the content and volume of processed personal data with the stated processing purposes;
• preventing the processing of personal data that is redundant in relation to the stated purposes of their processing;
• ensuring the accuracy, sufficiency and relevance of personal data in relation to the purposes of processing personal data;
• destruction or depersonalization of personal data upon achievement of the goals of their processing or in case of loss of the need to achieve these goals, if the Operator cannot eliminate the violations of personal data, unless otherwise provided by federal law.

Terms of personal data processing

The operator processes personal data if at least one of the following conditions is met:

• processing of personal data is carried out with the consent of the subject of personal data to the processing of his personal data;
• the processing of personal data is necessary to achieve the goals provided for by an international treaty of the Russian Federation or the law, for the implementation and fulfillment of the functions, powers and obligations imposed by the legislation of the Russian Federation on the operator;
• the processing of personal data is necessary for the administration of justice, the execution of a judicial act, an act of another body or official, subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings;
• the processing of personal data is necessary for the execution of an agreement to which the subject of personal data is a party or a beneficiary or guarantor, as well as for concluding an agreement on the initiative of the subject of personal data or an agreement under which the subject of personal data will be a beneficiary or guarantor;
• the processing of personal data is necessary to exercise the rights and legitimate interests of the operator or third parties or to achieve socially significant goals, provided that this does not violate the rights and freedoms of the subject of personal data;
• processing of personal data is carried out, access of an unlimited number of persons to which is provided by the subject of personal data or at his request (hereinafter - publicly available personal data);
• processing of personal data subject to publication or mandatory disclosure in accordance with federal law.

Confidentiality of personal data

The operator and other persons who have gained access to personal data are obliged not to disclose to third parties and not to distribute personal data without the consent of the subject of personal data, unless otherwise provided by federal law.

Publicly available sources of personal data

In order to provide information, the Operator may create publicly available sources of personal data of personal data subjects, including directories and address books. With the written consent of the subject of personal data, publicly available sources of personal data may include his last name, first name, patronymic, date and place of birth, position, contact phone numbers, e-mail address and other personal data provided by the subject of personal data.

Information about the subject of personal data should at any time be excluded from publicly available sources of personal data at the request of the subject of personal data, an authorized body for the protection of the rights of subjects of personal data, or by a court decision.

Ordering the processing of personal data to another person

The operator has the right to entrust the processing of personal data to another person with the consent of the subject of personal data, unless otherwise provided by federal law, on the basis of an agreement concluded with this person. A person who processes personal data on behalf of the Operator is obliged to comply with the principles and rules for processing personal data provided for by Federal Law 152 and this Policy.

Processing of personal data of citizens of the Russian Federation

In accordance with Article 2 of the Federal Law of July 21, 2014 N 242-FZ "On Amendments to Certain Legislative Acts of the Russian Federation in terms of clarifying the procedure for processing personal data in information and telecommunication networks" when collecting personal data, including through the information and telecommunication network "Internet", the operator is obliged to ensure the recording, systematization, accumulation, storage, clarification (update, change), extraction of personal data of citizens of the Russian Federation using databases located on the territory of the Russian Federation, except for the cases:

• the processing of personal data is necessary to achieve the goals provided for by an international treaty of the Russian Federation or the law, for the implementation and fulfillment of the functions, powers and obligations imposed by the legislation of the Russian Federation on the operator;
• the processing of personal data is necessary for the administration of justice, the execution of a judicial act, an act of another body or official, subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings (hereinafter referred to as the execution of a judicial act);
• processing of personal data is necessary to exercise the powers of federal executive bodies, bodies of state extra-budgetary funds, executive bodies of state power of the constituent entities of the Russian Federation, local government bodies and the functions of organizations involved in the provision of state and municipal services, respectively, provided for by the Federal Law of July 27 2010 N 210-FZ & nbsp; "On the organization of the provision of state and municipal services", including the registration of the subject of personal data on a single portal of state and municipal services and (or) regional portals of state and municipal services;
• the processing of personal data is necessary for the implementation of the professional activity of a journalist and (or) the legitimate activity of the media or scientific, literary or other creative activity, provided that this does not violate the rights and legitimate interests of the subject of personal data.

Cross-border transfer of personal data

The operator is obliged to make sure that the foreign state, to whose territory it is supposed to transfer personal data, provides adequate protection of the rights of subjects of personal data, prior to the start of such transfer.

Cross-border transfer of personal data on the territory of foreign states that do not provide adequate protection of the rights of subjects of personal data may be carried out in the following cases:

• the presence of written consent of the subject of personal data for the cross-border transfer of his personal data;
• the performance of a contract to which the personal data subject is a party.

Rights of the personal data subject

Consent of the subject of personal data to the processing of his personal data

The subject of personal data decides on the provision of his personal data and agrees to their processing freely, of his own free will and in his interest. Consent to the processing of personal data can be given by the subject of personal data or his representative in any form that allows to confirm the fact of its receipt, unless otherwise provided by federal law.

Rights of the personal data subject

The subject of personal data has the right to receive information from the Operator regarding the processing of his personal data, if such a right is not limited in accordance with federal laws. The subject of personal data has the right to demand that the Operator clarify his personal data, block or destroy them if the personal data is incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing, as well as take measures provided for by law to protect their rights .

The processing of personal data in order to promote goods, works, services on the market by making direct contacts with the subject of personal data (potential consumer) using communication means, as well as for political campaigning is allowed only with the prior consent of the subject of personal data.

The operator is obliged to immediately stop, at the request of the subject of personal data, the processing of his personal data for the above purposes.

It is forbidden to make decisions on the basis of solely automated processing of personal data that generate legal consequences in relation to the subject of personal data or otherwise affect his rights and legitimate interests, except for cases provided for by federal laws, or with the consent in writing of the subject of personal data .

If the subject of personal data believes that the Operator is processing his personal data in violation of the requirements of FZ-152 or otherwise violates his rights and freedoms, the subject of personal data has the right to appeal against the actions or inaction of the Operator to the Authorized body for the protection of the rights of subjects of personal data or in court.

The subject of personal data has the right to protect his rights and legitimate interests, including compensation for damages and (or) compensation for moral damage.

Ensuring the security of personal data

The security of personal data processed by the Operator is ensured by the implementation of legal, organizational and technical measures necessary to meet the requirements of federal legislation in the field of personal data protection.

To prevent unauthorized access to personal data, the Operator applies the following organizational and technical measures:

• appointment of officials responsible for organizing the processing and protection of personal data;
• limitation of the list of persons admitted to the processing of personal data;
• familiarization of subjects with the requirements of federal legislation and regulatory documents of the Operator on the processing and protection of personal data;
• organization of accounting, storage and circulation of media containing information with personal data;
• identification of threats to the security of personal data during their processing, formation of threat models on their basis;
• development of a personal data protection system based on a threat model;
• checking the readiness and effectiveness of using information security tools;
• differentiation of user access to information resources and software and hardware for information processing;
• registration and accounting of actions of users of personal data information systems;
• using antivirus and personal data protection system recovery tools;
• use, where necessary, firewalling, intrusion detection, security analysis and cryptographic protection of information;
• organization of access control to the territory of the Operator, security of premises with technical means for processing personal data.

Ensuring the security of personal data

The security of personal data processed by the Operator is ensured by the implementation of legal, organizational and technical measures necessary to meet the requirements of federal legislation in the field of personal data protection.

To prevent unauthorized access to personal data, the Operator applies the following organizational and technical measures:

• appointment of officials responsible for organizing the processing and protection of personal data;
• limitation of the list of persons admitted to the processing of personal data;
• familiarization of subjects with the requirements of federal legislation and regulatory documents of the Operator on the processing and protection of personal data;
• organization of accounting, storage and circulation of media containing information with personal data;
• identification of threats to the security of personal data during their processing, formation of threat models on their basis;
• development of a personal data protection system based on a threat model;
• checking the readiness and effectiveness of using information security tools;
• differentiation of user access to information resources and software and hardware for information processing;
• registration and accounting of actions of users of personal data information systems;
• using antivirus and personal data protection system recovery tools;
• use, where necessary, firewalling, intrusion detection, security analysis and cryptographic protection of information;
• organization of access control to the territory of the Operator, security of premises with technical means for processing personal data.

Final Provisions

Other rights and obligations of the Operator in connection with the processing of personal data are determined by the legislation of the Russian Federation in the field of personal data.