Terms of personal data processing
Personal data manager
Pididomek z.s. is the administrator of the personal data of the children's group Pididomek Praha, the children's group Pididomek Mladá Boleslav and the children's group Pididomek Jesle Mladá Boleslav. (hereinafter referred to as "Pididomek"), IČO 05109582, registered office: Žitomírská 640/3, 100 00 Prague 10, L 65731, registered at the Municipal Court in Prague. Pididomek Mladá Boleslav z.s. is the administrator of the personal data of Pididomek kindergarten. (hereinafter referred to as "Pididomek"), IČO 06584845, registered office: Náměstí Míru 14, Mladá Boleslav 293 01.
Purpose of this document
The purpose of this document is to fulfill our obligations in relation to the protection of personal data resulting from the EU Regulation 2016/679 of April 27, 2016 on the protection of natural persons in connection with the processing of personal data, hereinafter referred to as "GDPR" and other personal data protection regulations. The aim is to inform about the processing of personal data and the rights that children or their legal representatives apply. Information on the processing of personal data is available on the Pididomek bulletin board and will be continuously updated.
1. What personal data does Pididomek process?
Pididomek processes only such data as is necessary for the performance of the activities that the children's group is supposed to perform on the basis of relevant legal regulations and for the protection of the public interest and the legitimate interests of Pididomek and third parties. Pididomek also processes data that the child's legal representatives have given us consent to process.
These are the following data, mainly about the child and, to a lesser extent, about the legal representative, family members, or authorized persons (e.g. for pick ups):
- Identification data – personal data used for unambiguous and unmistakable identification, especially name, surname, social security number, date of birth, address of permanent residence, signature.
- Contact data – personal data enabling contact with legal representatives, in particular the specified contact address, telephone number, e-mail address and other similar information.
- Educational data – data on the child's development during the visit to Pididomek (motor skills, social behavior, self-sufficiency, speech skills, etc.).
- Communication data – electronic and written communication between the child's legal representative and Pididomek.
- Profile data – socio-demographic characteristics (marital status, siblings, etc.), behavioral, knowledge, skill and psychosocial characteristics of the child.
- Data on health status – data on health status includes, in particular, data on vaccinations, health restrictions, acute and chronic diseases, allergies, injuries, psychological diagnoses.
- Data on parents' employment and education - employer's confirmation of the employment of one of the parents during the child's visit to Pididomek (in the case of self-employed parents, this is a social insurance statement). Monitoring sheet with identification data and level of education achieved.
2. From what sources does Pididomek have personal data?
The personal data that Pididomek processes come mainly from the legal representatives of the child (at the time of admission and during further communication during the care and education of the child). An important source is also the child's observation by Pididomek employees. Last but not least, Pididomek can obtain data from health facilities and educational and psychological counseling services.
3. Are you obliged to provide personal data to Pididomek?
The legal representative is obliged to hand over most of the data. These are the data that Pididomek requires from its legal representatives, especially as part of registration in Pididomek. Without this data, Pididomek would not be able to ensure the fulfillment of obligations imposed by law (protecting children's health, keeping documentation and records, achieving the Education and Care Plan) or obligations arising from grant agreements. Pididomek does not ask for data that Pididomek does not need to fulfill its legal tasks.
4. Why and how does Pididomek process personal data?
Each processing of personal data has its own purpose or reason. To be legal, it must also have its own legal basis. This means they must be consent-based or necessary to:
- Negotiate the conclusion of a contract or for the performance of a contract
- Fulfill all legal obligations
- Complete tasks performed in the public interest or in the exercise of public authority
- Protect the legitimate interest of Pididomek or a third party
The purposes of processing personal data in Pididomek are as follows:
Ensuring proper registration in Pididomek and fulfillment of registration obligations - Data collection and registration is required by Act No. 247/2014 Coll. - Act on the provision of child care services in children's groups and on the amendment of related laws (Zákon o dětské skupině) and Act No. 561/2004 Coll. - Act on preschool, elementary, secondary, higher vocational and other education (Školský zákon). Pididomek is obliged to keep registration sheets and contracts with parents, which include personal data of children and legal representatives.
Ensuring education and care in a children's group – Based on the Act on Children's Groups, the Pididomek provides care and education according to the Plan of Education and Care and the kindergarten according to the school's educational program (hereafter referred to as "ŠVP"). For this purpose, it processes specific profile data and obtains additional information from legal representatives or medical facilities in the case of children with special educational needs. The Pididomek can request the completion of a questionnaire, which will allow you to get to know the child and his characteristics before he starts and thus facilitate his adaptation to the Pididomek environment. Last but not least, a book of accidents or medical reports is kept. A chronicle with daily records and evaluations is kept to record the children's progress and development.
Meals – Pididomek provides lunches for children based on a supply contract with a caterer. Snacks are provided by Pididomek. For this purpose, we collect and processes information about health restrictions relevant to the preparation and serving of meals.
Communication with legal representatives – Pididomek communicates with legal representatives about all matters related to education and care, health situation, the progress of implementation of the Education and Care Plan, ŠVP and events of Pididomek via e-mails and internal newsletters. Without this communication, it would not be possible to fulfill the objectives of the Education and Care Plan and the ŠVP. This is not a marketing communication. Pididomek can send newsletters with invitations to summer holiday programs, lectures or other relevant events organized by Pididomek to parents even after the child has stopped attending Pididomek. Parents can unsubscribe from newsletters at any time electronically.
Picking up children by third parties – Pididomek is authorized to process the contact details of third parties who will be allowed to pick up the child from the premises of Pididomek. By filling in contact information for third parties, the legal representative declares that he is authorized to grant such consent on behalf of third parties.
Provision of information to state institutions – Pididomek is obliged to provide registration sheets, contracts with parents, possibly data on parents' employment or social insurance statements and monitoring sheets during inspections by the Ministry of Labor and Social Affairs. Pididomek is obliged to provide registration sheets and contracts with parents during inspections by the Czech School Inspectorate. These controls result from grants and subsidies that partially cover the operation of Pididomek. Furthermore, Pididomek may be called upon to provide the necessary information to state institutions, e.g. the HMP Hygienic Station during an inspection or trial in civil or criminal matters, if they relate to the education, upbringing and care of a child.
Billing of school fees and meals - data is provided to a minimum extent. The first and last name of the parent is indicated on the invoice issued by the payroll accountant.
Publication of children's names/nicknames and their artistic creations in the changing area - based on the legitimate interest of the Pididomek and the children's parents, this information is accessible only to persons authorized to enter the Pididomek. In addition, children's unsigned creations can be published on Instagram for the purposes of art education documentation according to the Plan of Education and Care and the Education and Training Program.
Publication of photographs of the child – Based on its legitimate interest, Pididomek can document and inform about activities that result from the annual Education and Care Plan with monthly themes or ŠVP on its web profile, Facebook and on online repositories that meet the conditions of the GDPR. Photos are accessible to parents, among other things, in the ClassDojo app, which only logged-in parents can access. These are mostly group photos that are not provided with identification of the photographed persons. Pididomek can only use individual photos of children taken for promotional purposes with the consent of the parents.
5. In which cases can you object to the processing of data necessary to protect our legitimate interest?
Personal data protection legislation protects not only the person whose data is being processed (the data subject), but to a certain extent also the one who is processing it (the administrator). The protection of the legitimate interest of the administrator (Pididomek) or a third party (e.g. a child's legal representative) is one of the legal bases for the processing of personal data. It can only be used for processing that the data subject can expect and that will not result in a disproportionate interference with privacy or rights. At the same time, everyone has the right to file an objection against any processing necessary to protect the administrator's legitimate interest.
Pididomek processes personal data based on legitimate interest in the following cases:
- Publication of children's names and nicknames in the changing room, bulletin boards with children's artwork, descriptions of signs in the changing rooms.
- Publication of photos that document the fulfillment of the annual Education and Care Plan or ŠVP on www.pididomek.cz, Facebook or on encrypted online storages that comply with GDPR principles. Children's creations can be published on Pididomek's Instagram account. We only add the results of children's creative work on Instagram.
6. How long does Pididomek keep personal data?
Pididomek keeps personal data relating to the child based on the obligation stipulated in the grant agreement with the Ministry of Education and Culture and the Act on Children's Groups, not only during the child's attendance, but also after it ends within the statutory time limits. This is a period of 10 years.
Kindergarten Pididomek Mladá Boleslav z.s. keeps documents within the specified time limits according to the Archiving and File Regulations.
7. To whom can Pididomek transfer personal data?
Personal data is transferred in cases where it is required by law (e.g. Hygienic station HMP). Recipients of data can also be companies that Pididomek entrusts with a certain activity for the performance of which processing of personal data is necessary, e.g. Aperus s.r.o. IČO 28863976, which manages the Webooker attendance system based on the order of the operator of children's groups and the Pididomek kindergarten. The attendance system has personal data protection in accordance with the GDPR. To a limited extent, the recipient of personal data is our accountant Ildikó Dostálová, IČO 64870201. The recipient of the data available on the Pididomek website and the Pididomek Facebook profile are parents and the public.
8. What rights do you have in connection with the processing of personal data?
The right to access your data – you have the right to information about what data Pididomek processes and other related information (e.g. purpose, category of personal data, retention period, source). You have the right to request a copy of the processed personal data. However, for its repeated provision, it is possible to charge a fee corresponding to the costs of processing and providing the information.
The right to data portability - if it will be useful for you, for example, to facilitate communication with another nursery or kindergarten when changing, you can receive the data we have obtained from you from Pididomek.
Right to rectification of personal data – if your data or data about your child are incorrect, inaccurate or incomplete, you have the right to request rectification.
The right to erasure of personal data – Pididomek deletes your personal data itself within the statutory archiving periods. So you don't have to worry about erasing them. You can still exercise the right for erasure.
The right to limit the processing of personal data - in some situations Pididomek will limit the processing of personal data. For example, if Pididomek will deal with an objection to the processing of personal data or a warning about the inaccuracy of data.
The right to revoke consent - if you have given Pididomek consent to the processing of personal data - photos, you have the right to revoke it at any time with effect from the date of signing the revocation, i.e. to photographs taken from the date of recall.
The right to object - the right to object can only be exercised against processing based on the protection of the legitimate interest of Pididomek and third parties.
The right to file a complaint with the ÚOOÚ - every legal representative of a child has the right to file a complaint in matters of personal data protection with the Office for Personal Data Protection.
Validity: from 25 May 2018
Update: September 1, 2022
Translation: September 1, 2022
Ing. Anna Dostalová