Privacy Policy

1. LEGAL FRAMEWORK & SCOPE

This document (the “Policy”) outlines the data processing activities of the Romanian GCSE Campaign (the “Campaign”), a non-incorporated community-led initiative. This Policy is drafted in strict adherence to:

  • The Privacy and Electronic Communications Regulations (PECR).
  • The UK General Data Protection Regulation (UK GDPR);
  • The Data Protection Act 2018 (DPA 2018);

2. DATA CONTROLLER IDENTIFICATION

In accordance with Article 4 (7) of the UK GDPR, the Data Controller responsible for your personal data is:

  • ICO Status: Under registration
  • Individual Lead: Georgiana Anghel
  • Legal Status: Representative of an Unincorporated Volunteer Association.
  • Official Correspondence: hellp@romaniangcse.co.uk

3. CATEGORIES OF DATA COLLECTED

We collect and process the following categories of personal data via the website and integrated third-party modules:

  • Technical Data: Internet Protocol (IP) address, browser type and version, time zone setting, browser plug-in types, operating system, and platform.
  • Identity Data: Full name, preferred title.
  • Contact Data: Residential address, personal email address, telephone number.
  • Role-Specific Data: Student status, parent/guardian status, or volunteer interest.

4. COOKIE DISCLOSURE (PECR COMPLIANCE)

Our website utilizes a multi-layered cookie strategy. Cookies are small data files stored on your device.

4.1. Strictly Necessary Cookies (Exempt from Consent)

These are essential for the operation of the site. They include cookies that enable you to navigate the site and use secure features, such as the enrolment portal.

  • Lawful Basis: Legitimate Interest (Art. 6(1)(f) UK GDPR).

4.2. Analytical & Performance Cookies

We utilize these to monitor traffic patterns and campaign reach.

  • Lawful Basis: Consent (Art. 6(1)(a) UK GDPR).
  • Mechanism: These are only deployed upon your explicit “Opt-In” via our Cookie Consent Banner.

4.3. Third-Party Web Beacons & Cookies (Jotform Integration)

The enrolment form is hosted by Jotform Inc. (San Francisco, CA). When interacting with the form, Jotform may deploy functional cookies for session management and security (e.g., bot detection).

  • Critical Disclosure: Data entered into these forms is processed by Jotform on our behalf.

5. INTERNATIONAL DATA TRANSFERS (ARTICLE 44-46)

As we utilize Jotform (a US-based entity), your personal data is transferred to and stored in the United States.

  • Safeguards: We rely on Standard Contractual Clauses (SCCs) and the UK Extension to the EU-US Data Privacy Framework to ensure a level of protection equivalent to that of the UK. By submitting your data, you explicitly acknowledge this cross-border transfer.

6. DATA RETENTION POLICY

We adhere to the principle of “Storage Limitation” (Art. 5(1)(e)).

  • Campaign Duration: Data is retained for the active life of the Romanian GCSE Campaign.
  • Disposal: Upon the campaign’s conclusion or the successful implementation of the GCSE curriculum, all personal datasets will be permanently deleted or anonymized, unless a statutory retention period applies.

7. LAWFUL BASIS FOR PROCESSING

We process your data only when:

  • Consent: You have given clear consent for us to process your personal data for a specific purpose (Enrolment/Updates).
  • Legitimate Interests: It is necessary for our legitimate interests as a community group to promote the Romanian language in the UK education system, provided your fundamental rights are not overridden.

8. DATA SUBJECT RIGHTS (ARTICLES 15-22)

Under UK law, you possess the following enforceable rights:

  • Right to Lodge a Complaint: You have the right to contact the Information Commissioner’s Office (ICO)(www.ico.org.uk).
  • Right of Access: Obtain a copy of your personal data.
  • Right to Erasure (“Right to be Forgotten”): Request deletion of your data when it is no longer necessary.
  • Right to Rectification: Correct inaccurate information.
  • Right to Withdraw Consent: You may revoke consent at any time without affecting the lawfulness of processing based on consent before its withdrawal.

9. OPT-OUT & LIAISON

To exercise any of the aforementioned rights, or to “Opt-Out” of further communications, please contact the Lead Controller directly:

  • By Email: hello@romaniangcse.co.uk (Subject: DATA SUBJECT REQUEST)

Last Revised: March 31, 2026

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