Audio & Video Recording Policy

Introduction

University of Limassol, (hereinafter referred to as "UoL", “we”, “our”, “us”), is a progression of the Cyprus International Institute of Management (CIIM), a renowned business school operating in Cyprus since 1990 when it was founded as a Private School of Higher Education, by a group of leading executives of the Cypriot economy and renowned academics from leading Universities overseas.

The University respects your privacy and is committed to protect your personal data in accordance with the privacy and data protection regulation (GDPR). Therefore, you are kindly asked to read carefully the below policy for your information and please do not hesitate to contact us for any further clarification you might need.

The Audio and Video Recording Policy (hereinafter referred to as the Policy) describes how UoL collects, uses, and discloses certain personal information through the online platforms which may include audio and video recording, web streaming during meetings, events, conferences, e- classes and the way these will be processed.

The collection and processing of personal data is carried out in accordance with the principle of purpose limitation, which requires that data be collected for specified, explicit, and legitimate purposes and not further processed in a manner incompatible with those purposes.

In addition, we adhere to the principle of data minimisation, meaning that we collect and process only the data necessary to achieve the intended purpose—namely, the provision of online education as stipulated in the contract between us. This is done by requesting only essential information while allowing the voluntary provision of additional data. For example, participants may choose to send a written message to the teacher during a lecture rather than using a microphone.

Accordingly, data collection is lawful and consistent with the principles of purpose limitation, data minimisation, and necessity.

The Processing purpose is:

• to provide you with access in our e-learning management platform;
• to authorise you uploading video-recorded presentations your assignments related to the e-learning studies you have been registered;
• to grant you access on (e-)Lectures and video recordings of live sessions;
• to grant you access on oral online examinations;
• to grant you access on written online examinations;
• to provide you with examination results and final grading;

Categories of Personal Information we collect:

• Name, surname for the use of online platforms
• IP addresses
• Email details
• Pictures or facial images are only collected if you have uploaded and stored your profile picture on the learning management platform (LMS) we use for educational purposes. Please note that providing a picture or facial image is not mandatory; you may choose not to upload a profile photo on the LMS.
• Any video-recorded presentations as part of your individual or group assignments, which may include voice and image recorded during an oral online examination and/or a presentation which is uploaded by the student to the platform.
• Image, sound and video recorded during a written online examination, where you should activate your camera and your microphone.

Legal basis for the processing:

The collection and processing of the personal data in the manner described above is necessary:

• in compliance to the agreement between the student and UoL for the provision by UoL of the educational services, i.e. participation in the courses/ eLearning program where you have been registered and online examinations for the relevant degree and the provision by UoL to all students accessing appropriate learning material concerning their courses and/or program of study, including audio-visual recordings of relevant Sessions; or
• where processing is necessary for reasons of public interest in the field of public health. The provisions by UoL of the participation in online sessions and/or examinations, for example: when due to extraordinary circumstances, such as during a pandemic or other event giving rise to health or safety issues, UoL is unable to provide its services with the physical presence of students at our premises;

Retention of the data is based on:

• Our obligation to comply with the guidelines and other requirements set by the Cyprus Agency of Quality Assurance and Accreditation in Higher Education (CY.Q.A.A.) for the purposes of accreditation and quality assurance, including ensuring fairness in student assessment. This compliance is carried out in accordance with the competences of CY.Q.A.A. under applicable law;

Important note:

The use of a video camera during live sessions is not mandatory and aligns with the principle of data minimisation and purpose limitation under Article 5(1)(c) of the GDPR. Processing of the image and voice of students which is recorded when students choose to activate their camera during a lecture (e.g. to ask or answer a question or make a comment orally, instead of by written text) is based on the personal voluntary decision of the students, which is evidenced by the activation of their camera or microphone.

Data Sharing:

• We may share Personal Information with our service providers as necessary to respond to your requests—for example, to answer questions during a lesson, to grant access to a lesson following registration, or more generally, to facilitate the purposes described above, such as when you request to enrol in an online programme.
• We may also, in limited circumstances, share Personal Information with government authorities or others, as this is required in order to protect the interests of the UoL or others, as necessary in connection with the sale or transfer of all or a portion of the business, or as required by the law and or guidelines and other requirements by any relevant authority such us Cyprus Ministry of Education, Culture, Sport and Youth.

List of recipients we might disclose information:

• Affiliate companies – service providers (such as Law Firms for legal purposes, service providers for audit purposes, and LMS platforms including Teleconferencing provider if you choose an eLearning program)
• Third parties such as authorities, and administrative personnel (e.g. Cyprus Ministry of Education, Culture, Sport and Youth and CY.Q.A.A.)
• Legal Successors – we might disclose personal information to a buyer or a successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or sale or transfer of some or all of our assets

Retention/ storage of the data:

We follow a data retention policy, depending on the activity for which the data have been collected. The retention policy determines the retention time of each data and when to destroy information that is no longer needed for legal, regulatory or commercial reasons.

The recording of the students’ voice and image during a session, will be part of the audio-visual recording of the relevant session and, thus, will be available to the instructor (for use, where appropriate, for student assessment and/or course management purposes) and to all students of the class (for use for learning purposes during their studies, for a period of up to one (1) year as required by CY.Q.A.A.

The recording of the students’ voice and image during an examination will be storage for a period up to one (1) month.

Your rights according to GDPR:

1. Right of access - request access to any personal data we hold about you;
2. Right of rectification – request rectification and correction of any personal data which we hold about you which may be inaccurate or incomplete;
3. Right to be forgotten - have your personal data erased;
4. Right to restriction of processing – impose restrictions on the processing of your personal data;
5. Right of portability – to be provided with the personal data that you have supplied to us in a portable format that can be transmitted to another organisation without hindrance;
6. Right to object - object to certain types of processing, including processing based on legitimate interests, automated processing (which includes profiling) and processing for direct marketing purposes;
7. Right to object to automated processing, including profiling - not be subject to a decision that is based solely on automated processing which produces a legal effect, or which has a similar significant effect for the individual.

You may exercise any of your rights by contacting our Data Protection Officer at dpo@uol.ac.cy. Please be noted that some of these rights are restricted in some circumstances.

In case you have provided your consent to any of the processing of your personal data, you have the right to withdraw your consent at any time. For this purpose, you must also contact the Data Protection Officer.

Security measures:

The University (UoL) is fully aware of the security risks associated with data protection. As such, we have implemented a range of technical and organizational measures to safeguard the information we collect. These measures include, but are not limited to:

• Data processing agreements when disclosing information to third parties
• Regular data backups
• Robust firewalls
• Minimization of the information collected
• Encryption of the data
• Annual check reports
• Limitation of access to the data
• and many more.

Data Protection Officer:

You may contact UoL Data Protection Officer by sending an email at dpo@uol.ac.cy
If you require this Policy to be provided to you in paper form and/ or need any further clarification, please contact our Data Protection Officer using the contact details as described above.

Important Notice

The Privacy Policy and the Terms and Conditions for the use of Moodle are considered integral components of this Policy and are available for your review.

This Policy may be amended or updated from time to time at our discretion. We advise you to consult it regularly, especially prior to submitting further personal information. All modifications will be published on our website, and the effective date of the latest version will be clearly stated at the top of this page.