General Data Protection Regulation (GDPR) Framework
Purpose of this summary
In this summary we explain who we are, why we need your data, what we do with it and how we help you to exercise your rights with respect to your data.
Who we are
When you apply for a 10-day Vipassana course your data goes through an online application process called CALM (standing for Course Application and Letters Management). All affiliated Vipassana organisations use this registration system to organise courses.
Your data is used to process your application, provide you with a place on the course, a room and a place to meditate, and if necessary, to make special provisions for you.
Why we store your information
With the information you give us, we assess if you are mentally and physically capable of participating in a course. A Vipassana course can be very demanding.
We use your information in order to:
We will not do these things if you notify that you do not want us to.
There are cases, however, when we need to keep certain personal details because somebody could harm themselves or others by participating in a course.
The information we collect
We collect the following information: your name, date of birth, gender, profession, medical and/or mental health history (as provided by you), name of spouse, name of friends who are participating in the course, emergency contact, general contact information, your previous course history, native language and other languages spoken.
For the duration of the course we also store the licence plate number of your vehicle in case we need to remove it in an emergency.
If a teacher has grounds to decide that you cannot participate in a course, we will keep this information and the reason why. The decision may be based on data provided by you, but also on events or the observations made by a teacher. Only teachers involved with the assessment have access to this information.
How long it is stored
In CALM, all sensitive information and communication is removed 3 months after your course is completed. Only some basic information is stored, such as your name and if you completed a previous course.
An assessment that you cannot participate in a course in the future, or that you can participate only under certain conditions, is kept for a maximum of 10 years. This period can be prolonged after a new assessment.
Taking into account that Vipassana Association has no possibility and no sufficient resources to store the documents for a long period of time, paper application, which you complete upon arrival to the course, is sent for storage to Dhamma Dvara (Vipasaana-Vereingung e.V., having its registered office in Triebel, Germany), where it is destroyed upon expiry of 3 years as of the completion of the course. Vipassana Association (Lithuania) and Vipasaana-Vereingung e.V. (Germany) are responsible for protection of your personal data that were provided to them in compliance with applicable legislation.
However, we delete all information that we no longer need immediately after it becomes unnecessary to us.
In case you would need more details on the terms of storage of information, please contact the Data Protection Officer (DPO) or Privacy Contact Person (PCP) as indicated below.
How we process your personal information
When we process your personal information, we follow a set of below principles:
The Data Protection Officer (DPO) and Privacy Contact Person (PCP)
The CALM foundation, responsible for the international online registration system, has a Data Protection Officer. Meditation centres that use the system, like Vipassana Association, are responsible for the further processing. Therefore, each country has a Privacy Contact Person. The Privacy Contact Person co-operates with the Data Protection Officer to protect your data. You can contact any of them at: [email protected].
Personal information is only stored if we have a legitimate reason to collect it and if the law allows us to do so. For example, we collect personal information on the following grounds: by consent of a person, under a contract, because of any other legitimate interest (such as the vital interest of a student), or because a special law requires us to. We can always inform you of the legal reason why we are holding your information.
Fellow workers/volunteers who process data for Vipassana Association are bound by confidentiality undertakings signed by them. Only the teachers (who are also bound by written confidentiality undertakings), involved with an assessment, have access to very sensitive information. Your personal information is kept securely and is not in any circumstances disclosed to a third party, unless such third party has been specifically authorised to receive that information and have signed (provided this does not contradict the applicable law) a confidentiality undertaking.
Personal data is kept:
PC screens, monitors and terminals, used for processing data, are not visible except to authorised fellow workers/volunteers having the respective authorisations. Physical notes/records are not left where they can be accessed by unauthorised personnel and may not be removed from the workplace without prior authorisation.
We respect your rights. More specifically we ensure that:
Access to information and objections towards the processing
If you want to find out what information we keep about you, or, if you do not agree with the data we keep, and if you want to submit an objection towards processing, you can fill in this form (Student Rights Form) and make the request by sending it to [email protected].
If there is a breach that may have repercussions for you, we will inform about this you and the Data Protection Authority. If you would like to report a breach, you can do it here: https://www.privacy-eu.dhamma.org/report-a-data-breach/.
Whenever we share your personal information with a Vipassana-organisation outside the European Union, we apply additional safeguards. To learn more about the safeguards we applied in your specific case, please contact us by e-mail [email protected].
In case you ask us to provide data to an organisation without adequate safeguards, we will inform you about the risks. In this case you will decide whether or not to provide the information to such organisation.