CIIM Audio & Video Recording Policy

CYPRUS INTERNATIONAL INSTITUTE OF MANAGEMENT LIMITED (hereafter “CIIM”) is a limited liability company, incorporated during 2008 under the Companies Law of the Republic of Cyprus, Cap. 113, under the given registration number HE 42590, having as main activities various aspects of the education industry.

The present Policy describes how CYPRUS INTERNATIONAL INSTITUTE OF MANAGEMENT LIMITED (hereafter “CIIM”), collects, uses, and discloses certain personal information through the online platforms which may include audio and video recording, web streaming during meetings, events, conferences, classes and the way these will be processed.

The Processing purpose is:

  • to provide you with access in our systems;
  • to provide you with access for uploading your coursework, presentations and responses to oral or written examinations;
  • to grant you access on Lectures;
  • 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 and password for the use of online platforms
  • IP addresses
  • Email details
  • Voice and image recorded during an oral online examination
  • Image, sound and other data recorded during a written online examination

Legal basis for the processing:

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

  • the provision by CIIM of the educational services, i.e. participation in the courses of Distance Learning programs of study and online examinations for the relevant degree;
  • in compliance to the agreement between the student and CIIM
  • the provision by CIIM 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, CIIM is unable to provide its services with the physical presence of students at our premises;
  • our obligation to comply with the guidelines and other requirements of the CY.Q.A.A. for accreditation and quality assurance purposes;
  • administration purposes: in order to ensure proper record keeping and administration of our programs of study and services, proper management and maintenance of our systems and resolution of any technical issues;
  • the provision by CIIM to all students accessing appropriate learning material concerning their courses and/or program of study, including audio-visual recordings of relevant Sessions.
  • ensuring fairness in assessing the students, and to the Cyprus Agency of Quality Assurance and Accreditation in Higher Education (Q.A.A.) for accreditation and quality assurance purposes pursuant to the competences of the CY.Q.A.A. under applicable law.
  • 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 decision of the students, which is evidenced by the activation of their camera or microphone.

Data Sharing:

  • We may share Personal Information amongst our affiliates for purposes of responding to your requests or otherwise as necessary for the purposes described above.
  • 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 CIIM 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 CY.Q.A.A

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 will thus 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 6 months).

The recording of the students’ voice and image during an examination will be storage for a period up to 6 months as required by CY.Q.A.A.

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; and
  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@aretilaw.com.

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.

Data Protection Officer:

CIIM has assigned ARETI CHARIDEMOU & ASSOCIATES L.L.C as the personal Protection Agent. Please see below the contact details:

Areti Charidemou & Associates LLC – Law Firm
21 Vasili Michailidi Street | 3026 Limassol – Cyprus
Postal Address: PO Box 54708 | CY-3727 | Cyprus
D: +357 25 50 82 19| T: +357 25 50 80 00 | F: +357 25 50 80 90
E: dpo@aretilaw.com