Integrity Policy

Personal data processing

Your private integrity is important to Berghs School of Communication (“Berghs”) and we protect our students’ and customers’ integrity. To be able to offer our services such as courses, programmes and events, we need to process your personal data. It is important to us that you understand and feel comfortable with the personal data processing that we perform. The purpose of this personal data policy is to inform you about what personal data about you we process, why and how we process it, what rights you have and what responsibility we have for your personal data. You are always welcome to contact us if you have any questions.

All information that can be directly or indirectly connected with you as a physical individual is considered to be personal data. When you apply for a programme of education on our website, contact us, use our teaching portal or register for an event or one of our news or information distributions, you provide us with your personal data. The personal data consists of name, personal ID number, e-mail address, telephone number and application documents such as grades, CV, certificates, portfolios etc. and invoice and home addresses. Data is also processed about how you use Berghs’ website and education portal (how you reached and left the page), IP address and geographical information.

Berghs’ processing of your personal data is in accordance with the General Data Protection Regulation (Regulation of the European Parliament and of the Council (EU) 2016/679 of 27 April 2016 “GDPR”). Among other things, this means that Berghs does not process your personal data to a greater extent than is necessary for the purposes of our educational activities or for other purposes than stated below.

Personal Data Controller

Berghs School of Communication AB, organisation number 556135-0355 (Sveavägen 34, Box 1380, SE-111 93 STOCKHOLM, telephone: 08-587 550 00, e-mail: info@berghs.se) is the personal data controller for the organisation’s processing of your personal data.

Categories of personal data, purposes, legal grounds and storage times

We process various categories of personal data with different purposes and legal grounds. The storage times also vary depending on the purpose for which we are processing your personal data. We present below each of the different processing types – so that you can easily read about the personal data processing that applies to you.

1. When you apply for an HVE programme (full-time education)

What is our purpose?

To be able to process your application for education and reach an admission decision, as well as to be able to communicate with you about the educational programme you have applied for.

When a doctor’s certificate or similar is needed, for example if you need special educational support, we also process sensitive data about you. This is done so that we are able to process your application, ensure your rights and fulfil our legal obligations.

What personal data is processed?

  • Personal ID number (if you have one)
  • First and last name
  • Telephone number
  • E-mail address
  • Home address
  • Postal town
  • Application documents in the form of CV, grades, certificates, portfolios and other information that is required for the HVE application.
  • Information about whether you are admitted or not
  • All the information is provided by you in connection with your application for education.

How do we use the information?

  • The application documents are assessed to decide whether you fulfil the qualification requirements of the programme for which you have applied. In connection with the assessment, a selection value is awarded to the application. This processing is done manually by an administrator at Berghs.
  • To notify you whether you have been admitted or not, as well as contacting you for any additional information for the application.
  • If you are admitted, we also need to send you study-related information.
  • Distribution to collaborating authorities, such as the Swedish National Agency for Higher Vocational Education (“MYH”), CSN and Statistics Sweden (with a request for statistical data).
  • IT sub-contractors within and outside Sweden are used in running our educational activities and, in performing services relating to websites, storage and the IT environment, these process your personal data. We have written processor agreements with all data processors in accordance with GDPR and thereby ensure a good level of security for your information. Your information is only processed by processors located within the European Economic Area (EU/EEA).
  • Your information is also shared with companies within the Intendia Group so as to be able to provide your education.
  • We will not transfer your information to any other third party unless we have an obligation to do so according to law or the decision of a court.
  • Your information will never be sold or transferred onward for direct marketing purposes by a third party.

Legal grounds

The processing that occurs is necessary so that we are able to make an admission decision according to the Act (2009:128) on Higher Vocational Education, the Regulation (2009:130) on Higher Vocational Education and in accordance with regulations issued by the Swedish National Agency for Higher Vocational Education (“MYH”). Performing these purposes is the exercise of authority and a task of general interest according to Swedish law.

Storage times

Regardless of whether you are admitted to a programme of education or not, we will keep your application information. We do this because we must keep documentation relating to the admission process and we must be able to demonstrate how cases are administered, for example if the MYH performs an inspection or if you wish to appeal the admission decision. If you are admitted to an HVE programme, your personal data will be processed in the way stated in point 2 – “Personal data processing during and after your HVE programme”.

If you are not accepted for an HVE programme, we still need to keep documentation of the admission process. This means that your personal data will be processed during the period of the programme to which you applied. After this, your personal data is deleted.

2. Personal data processing during and after your HVE programme

What is our purpose?

To be able to administrate your studies and grade, as well as to be able to issue examination/programme certificates after the programme has finished.

What personal data is processed?

  • Personal ID number (if you have one)
  • First and last name
  • Telephone number
  • E-mail address
  • Results of examination instances

Information is provided by you in connection with your application. Information about results, grades etc. is such information as we register/collect.

How do we use the information?

  • To be able to communicate course and programme related information to you.
  • Your information is saved in our database.
  • IT sub-contractors within and outside Sweden (but within the EU/EEA) are used in running our educational activities and, in performing services relating to websites, storage and the IT environment, these process your personal data. We have written processor agreements with all data processors in accordance with GDPR and thereby ensure a good level of security for your information.
  • Our staff, as well as the teachers and other teaching staff Berghs engages through consultancy and sub-contractor agreements, need access to your information so as to fulfil their duties.
  • Distribution to collaborating authorities, such as MYH, CSN and Statistics Sweden (with a request for statistical data).
  • Your information is also shared with companies within the Intendia Group so as to be able to provide your education.
  • We will not transfer your information to any other third party unless we have an obligation to do so according to law or the decision of a court.
  • When the programme has finished, information about study documentation is transferred to MYH.
  • Your information will never be sold or transferred onward for direct marketing purposes by a third party. Neither will it be transferred to any country outside the EU/EEA.

Legal grounds

Higher vocational education is under the supervision of MYH. This means that we must comply with the Act (2009:128) on Higher Vocational Education, the Regulation (2009:130) on Higher Vocational Education and regulations issued by MYH. We must therefore administrate your educational programme and process your personal data regarding the courses you take, grades, certificates and other documentation that is needed. Performing these purposes is the exercise of authority and a task of general interest according to Swedish law.

Storage times

According to the Regulation (2009:130) on Higher Vocational Education and regulations issued by MYH, we shall keep your study documentation during your study period so as to be able to issue educational and examination certificates. MYH also requires that , as organisers of education, we keep documents (i.e. study documentation about you) as long as the educational programme is included in the higher vocational education, up to and including two years after the decision to include it in the higher vocational education no longer applies. This means that as long as the educational programme taken by you is an HVE programme here (according to decision by MYH), the study documentation is kept.

To enable you to contact us later to request certificates, grades or other information about the studies you have completed, we keep your personal data for up to fifty (50) years after the educational programme has been completed. It is then deleted.

3. The 1 semester programme and course activity

What is our purpose?

  • To process the application process, fulfil agreements on places (if you are admitted) and to be able to issue certificates.
  • So that you are able to follow your educational programme.
  • You are not obliged to give out your personal data, but if you do not wish to give out your personal data this could mean that we are unable to offer you a place.

What personal data is processed?

  • Personal ID number (if you have one)
  • First and last name
  • Telephone number
  • E-mail address
  • Application documents (depending on the programme/course that is applied for), e.g. CV, grades, certificates, portfolios, personal letters.
  • Results of examination instances

Information is provided by you in connection with your application. Information about results, grades etc. is such information as we register/collect

How do we use the information?

  • We assess whether you are qualified for the educational programme applied for.
  • We award selection points and make a decision on admission.
  • If you are only applying for one course, your application is not awarded selection points.
  • To be able to communicate course and programme related information to you.
  • IT sub-contractors within and outside Sweden (but within the EU/EEA) are used in running our educational activities and, in performing services relating to websites, storage and the IT environment, these process your personal data. We have written processor agreements with all data processors in accordance with GDPR and thereby ensure a good level of security for your information.
  • Our staff, as well as the teachers and other teaching staff Berghs engages through consultancy and sub-contractor agreements, need access to your information so as to fulfil their duties.
  • To be able to administrate your studies, register grades and so as to be able to issue certificates after studies have been completed.
  • Your information is also shared with companies within the Intendia Group so as to be able to provide your education.
  • We will not transfer your information to any other third party unless we have an obligation to do so according to law or the decision of a court.
  • Your information will never be sold or transferred onward for direct marketing purposes by a third party. Neither will it be transferred to any country outside the EU/EEA.

Legal grounds

We process your personal data so as to fulfil the agreement (agreement on a place) to which you are party. To be able to fulfil the agreement we must process your data before the agreement is entered into; such processing occurs at your request in that you have applied for a place. To fulfil the agreement, e.g. in respect of issuing certificates etc., we must also perform actions after you have concluded your programme/courses.

Storage times

We process your personal data for as long as your programme/course continues. When you have finished your studies we save your information regarding your study documentation /grades, results, certificates, courses taken etc. for up to fifty (50) years. We do this so that, as a former student/course participant, you are able to request certificates and other information about the programme/course you have taken.

4. Bachelor programme

What is our purpose?

  • To process the application process, fulfil agreements on places (if you are admitted) and to be able to issue certificates.
  • When you take Berghs Bachelor, most of your tuition occurs at Berghs’ partner schools abroad. Your personal data is therefore also processed for the administration of this part.
  • So that you are able to follow your educational programme.
  • You are not obliged to give out your personal data, but if you do not wish to give out your personal data this could mean that we are unable to offer you a place.

What personal data is processed?

  • Personal ID number (if you have one)
  • First and last name
  • Telephone number
  • E-mail address
  • Application documents in the form of CV, grades, certificates, portfolio
  • Results of examination instances

Information is provided by you in connection with your application. Information about results, grades etc. is such information as we register/collect.

How do we use the information?

  • We assess whether you are qualified for the educational programme applied for.
  • We award selection points and make a decision on admission.
  • To be able to communicate course and programme related information to you.
  • IT sub-contractors within and outside Sweden (but within the EU/EEA) are used in running our educational activities and, in performing services relating to websites, storage and the IT environment, these process your personal data. We have written processor agreements with all data processors in accordance with GDPR and thereby ensure a good level of security for your information.
  • Our staff, as well as the teachers and other teaching staff Berghs engages through consultancy and sub-contractor agreements, need access to your information so as to fulfil their duties.
  • Your grades (which represent personal data) will be transferred to relevant partner schools to make your study administration easier. This means that your personal data is transferred to other countries – see “*Special information for those taking Berghs Bachelor.”
  • To be able to administrate your studies, register grades and so as to be able to issue certificates after studies have been completed.
  • We will not transfer your information to any other third party unless we have an obligation to do so according to law or the decision of a court.
  • Your information will never be sold or transferred onward for direct marketing purposes by a third party.

Legal grounds

We process your personal data so as to fulfil the agreement (agreement on a place) to which you are party. To be able to fulfil the agreement we must process your data before the agreement is entered into; such processing occurs at your request in that you have applied for a place. To fulfil the agreement, e.g. in respect of issuing certificates etc., we must also perform actions after you have concluded your programme.

Storage times

We process your personal data for as long as you are a student with us. When you have finished your studies we save your information regarding your study documentation /grades, certificates, courses taken etc.) for up to fifty (50) years. We do this so that, as a former student, you can request certificates and other information about completed studies.

*Special information for those taking Berghs Bachelor

Personal data that Berghs partner schools in Australia and the USA process is not covered by GDPR since the partner schools are outside the EU/EEA. There is no decision from the European Commission regarding a so-called adequate protection level for personal data that is applicable for the partner schools in Australia and the USA. This means that Berghs cannot guarantee that your personal data is processed with a level of protection that is equivalent to what applies according to GDPR. If you are admitted for studies at a foreign educational institution through Berghs and third party transfer is needed, you will receive specific information about this and given the opportunity to specifically consent to the transfer of your personal data to a country outside the EU/EEA.

With regard to partner schools within the EU/EEA, your personal data is processed at the partner schools in accordance with GDPR.

5. Other processing of your personal data – regardless of which programme you are taking

What is our purpose?

To improve our level of education, inform you about what other services we offer and to communicate other news to you. The possibility of issuing invoices for the programme you are taking and bookkeeping for the purpose.

What personal data is processed?

  • Name
  • E-mail address
  • Invoice address
  • What educational programme you are taking

The information comes from the information you supplied when you applied/registered for a programme. We have collected the information about which programme you are taking based on our admissions

How do we use the information?

  • Berghs uses your information so as to be able to contact you regarding participation in surveys in relation to your educational programme.
  • To contact you by e-mail with information about future events, other courses of education and other news.
  • To be able to invoice and perform our ongoing bookkeeping.
  • We share your personal data with our IT suppliers (personal data processors). We have written processor agreements with all data processors in accordance with GDPR and thereby ensure a good level of security for your information.
  • We will not transfer your information to any other third party unless we have an obligation to do so according to law or the decision of a court.
  • Your information will never be sold or transferred onward for direct marketing purposes by a third party.

Legal grounds

The processing of your personal data in order to enable our bookkeeping obligations continues for up to seven years after the end of the financial year. We thus have a legal obligation to process your personal data (name and invoice address) during this period.

Berghs justifies its personal data processing by means of a balance of interests in which we judge that we have legitimate interests in quality control, compiling statistics and basic survey data so as to have the opportunity to offer goo educational activities. After careful consideration, Berghs has found that your interests or basic rights and freedoms in this context do not outweigh the above or require protection of personal data, but that we as organisers of education can process a statistical basis for developing our activities.

We also judge that you, in being a part of the activities, are interested in receiving information about coming events, other educational programmes and other news about the activities, for which reason we judge that we have a legitimate interest in producing a basis for marketing and in marketing our services to you. After careful consideration, Berghs has found that your interests or basic rights or freedoms in this context do not outweigh the above or require protection of personal data, for which reason Berghs can justify processing on the basis of the above legitimate interests.

Storage times

Berghs keeps your personal data for the above purposes for up to a year after the educational programme has finished. We judge that thereafter we do not have an interest in processing your data for the purpose in question.

In the event that you do not wish to receive customer satisfaction surveys or our marketing, you can register this at any time  – either by e-mail to info@berghs.se, or by following the link that can be found in every e-mail. On receipt of such a request, Berghs will immediately cease processing your information for marketing purposes.

6. Personal data processing when you register for an event

What is our purpose?

To fulfil our obligations (i.e. organise events for which you have registered), perform customer satisfaction surveys and inform you about coming events and other news.

What personal data is processed?

  • Name
  • E-mail address
  • Information about which event you participated in

All information is provided by you in your registration

How do we use the information?

  • Berghs uses your information so as to be able to organise the event.
  • To contact you about the event, e.g. if changes to time or venue occur, and to send you other event-related information.
  • To contact you about participating in customer satisfaction surveys.
  • To contact you by e-mail with information about future events and other news
  • Your personal data will be shared with companies in the Intendia Group.
  • We share your personal data with our IT suppliers (personal data processors). We have written processor agreements with all data processors in accordance with GDPR and thereby ensure a good level of security for your information.
  • We will not transfer your information to any other third party unless we have an obligation to do so according to law or the decision of a court.
  • Your information will never be sold or transferred onward for direct marketing purposes by a third party.

Legal grounds

Berghs processes your personal data so as to fulfil the agreement entered into in connection with event registration.

The personal data processing that occurs beyond this – i.e. contacting you regarding customer satisfaction surveys and informing you about coming events and news – is justified by a balance of interests. When you register for an event, you have demonstrated an interest in our services. We therefore believe that you are also interested in our forthcoming events and/or news about our activities, for which reason we judge that we have a legitimate interest in producing data for marketing and in marketing our services to you. We also have an interest in producing data for method and business development. After careful consideration, Berghs has found that your interests or basic rights or freedoms in this context do not outweigh the above or require protection of personal data, for which reason Berghs can justify processing on the basis of the above legitimate interests.

Storage times

Your personal data is kept for up to a year after your last customer contact with us. We judge that thereafter we do not have an interest in processing your data for the purpose in question.

In the event that you do not wish to receive our marketing, you can register this at any time – either by e-mail to info@berghs.se, or by following the link that can be found in every e-mail. On receipt of such a request, Berghs will immediately cease processing your information for marketing purposes.

7. Personal data processing when you register for Berghs newsletter

What is our purpose?

To market our services, events and other content in our marketing to you.

What personal data is processed?

  • Name
  • E-mail address

All information is provided by you in your subscription registration.

How do we use the information?

  • The information is used to send direct marketing messages to you via the e-mail address you have given.
  • Your personal data will be shared with companies in the Intendia Group.
  • We share your personal data with our IT suppliers (personal data processors). We have written processor agreements with all data processors in accordance with GDPR and thereby ensure a good level of security for your information.
  • We will not transfer your information to any other third party unless we have an obligation to do so according to law or the decision of a court.
  • Your information will never be sold or transferred onward for direct marketing purposes by a third party.

Legal grounds

Your personal data is processed so as to be able to fulfil the agreement that has been entered into with you when you registered as a subscriber. To be able to fulfil our obligations (i.e. issue the newsletter that you have advised you wish to have), we must process your personal data.

Storage times

We process your personal data during the period you are a subscriber to the newsletter. You can cancel your subscription at any time by following the link in every newsletter or by contacting info@berghs.se. When you end your subscription, our processing of your personal data ceases.

8. Berghs’ personal data processing when you use our website

What is our purpose?

To provide and improve our services

What personal data is processed?

  • IP address
  • Language settings
  • Geographical location
  • Information about how you interact with Berghs by means of processing information about how you reach and leave the service.

This information is processed using cookies, the purpose of which is analysis and visit statistics of the website and for market communication purposes. More information about how Berghs uses cookies can be found here.

The information is provided automatically by you when you visit our website.

How do we use the information?

  • We process the data so as to be able to improve our technical solutions.
  • IT sub-contractors within and outside Sweden are used in running our activities and, in performing services relating to websites, storage and the IT environment, these process your personal data. We have written processor agreements with all data processors in accordance with GDPR and thereby ensure a good level of security for your information.
  • We use the statistical tool Google Analytics to measure traffic on the website

Legal grounds

Berghs has a legitimate interest in running market and customer analysis, in method and business development and in collecting statistical data. In order to fulfil these interests, we must process your personal data as above. A balance of interests forms the legal grounds for this processing. After careful consideration, Berghs has found that your interests or basic rights or freedoms in this context do not outweigh the above or require protection of personal data, for which reason Berghs can justify processing on the basis of the above legitimate interests.

Storage times

Processing of personal data ceases when you close your web browser. Thus no personal data is kept about you as a visitor. The information that is processed after you have closed your web browser does not represent personal data and thus cannot be traced to you – you can read more about this processing here.

9. Berghs’ personal data processing when you use our education portal

What is our purpose?

To deliver educational content and allow communication between students, participants and teachers

What personal data is processed?

  • Name
  • E-mail address

The information is provided automatically when you go to a course or educational programme.

10. Berghs’ use of cookies

What are cookies?

Cookies are small text files consisting of letters and numbers. These are sent by Berghs, Berghs’ educational platform or our partners and are saved on your device as follows:
Session cookies are temporary cookies that cease when you close your web browser or app.
Persistent cookies are cookies are cookies that remain on your computer until you remove them or they expire.
First party cookies are cookies created by the domain that you are visiting.
Third party cookies are cookies created by third party sites.

Cookies & similar techniques

We use cookies, web beacons and similar techniques (jointly referred to as “cookies”) to improve your experience with us. We use cookies on our websites and in our services, such as in our educational platform. Below we explain how we use cookies and what choices you can make with regard to our cookies.
See also Berghs’ data protection policy regarding the processing of your personal data.

Web beacons are small, transparent graphic images that can be found in the e-mails we send you. Similar techniques refers to techniques that store information in your web browser or your device in a way that resembles cookies and web beacons.

Why do we use cookies?

The cookies that we use normally improve the services that we offer. Some of our services need cookies in order to function, while others exist to make our services better for you. In general, we categorise our cookies and their use as follows:

Essential cookies are necessary so as to be able to offer our basic services, such our education portal. Our services could not function without these cookies.

  • Analysis cookies provide overall analytical information about your use of our services. Our services could not function without these cookies.
  • Function cookies enable us to save settings such as choice of language or whether we shall fill in your information in advance or not.
  • Security cookies make our services and your data safe and secure by helping us to detect fraud and protect your data. Since this is a significant part of our services, these cookies are necessary.
  • Advertising cookies help us to direct relevant marketing information to you.

How can you control Berghs’ use of cookies?

Your web browser or device normally allows you to change the settings for the use and extent of cookies. Go to the settings for your web browser or device to learn more about how to adjust the settings for cookies. For example, you can choose to block all cookies, to only accept first party cookies or to erase cookies when you close your web browser.

How do we use the information?

  • IT sub-contractors within and outside Sweden (but within the EU/EEA) are used in running our activities and, in performing services relating to websites, storage and the IT environment, these process your personal data. We have written processor agreements with all data processors in accordance with GDPR and thereby ensure a good level of security for your information.
  • We will not transfer your information to any other third party unless we have an obligation to do so according to law or the decision of a court
  • Your information will never be sold or transferred onward for direct marketing purposes by a third party. Your personal data is not transferred to countries outside the EU/EEA.

Legal grounds

Berghs has a legitimate interest in running market and customer analysis, in method and business development and in collecting statistical data. In order to fulfil these interests, we must process your personal data as above. A balance of interests forms the legal grounds for this processing. After careful consideration, Berghs has found that your interests or basic rights or freedoms in this context do not outweigh the above or require protection of personal data, for which reason Berghs can justify processing on the basis of the above legitimate interests.

Storage times

Your personal data is used for this purpose for up to six (6) months after the end of the course or educational programme, after which the processing ceases. If your personal data (name and e-mail) is not needed for some other stated purpose with a longer storage time, it is deleted.

Your rights

Berghs has no right to use your personal data for purposes other than those stated above unless you first receive information about this. Berghs does not use any form of automated decision making (including profiling).

You can approach Berghs at any time with questions about how we process your personal data (info@berghs.se). You have the right to request, at no charge, an extract from the register, i.e. access to your saved personal data. The extract from the register is sent to your registered address.

You also have the right to present the following requests: 1) if you think that your personal data that is registered with us is incorrect or incomplete you have the right to request correction 2) the right to request deletion of your data 3) the right to request that we restrict our processing of your personal data 4) the right to request the transfer of your personal data (data portability) to another service provider in a commonly used, machine readable format . If you contact info@berghs.se your request will be considered and if it is justified we will take the action you have requested, as far as we are able to do so.

You also have the right to object to our processing (as described above) of your personal data.

Complaint

If you are dissatisfied and have a compliant about any part of Berghs’ processing of your personal data, you have the right to submit a complaint to the supervisory authority, the Swedish Data Protection Authority (www.datainspektionen.se, datainspektionen@datainspektionen.se, telephone number: 08 657 61 00).

Last updated 24/04/2018