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Personal Data Processing Policy

1. General Provisions

 

1.1. The Personal Data Processing Policy (hereinafter — the Policy) of the Autonomous Non-Profit Organization “Innovation Agency” (hereinafter — the Agency) has been developed to implement the requirements of Clause 2, Part 1, Article 18.1 of Federal Law No. 152-FZ “On Personal Data” dated July 27, 2006, and applies to the personal data that the Agency may receive from data subjects.

1.2. The Policy is the foundational document defining the general principles, procedures, and conditions for processing personal data, the rights and obligations of the operator and data subjects, as well as the security measures applied during processing.

1.3. The purposes of the Policy are: to ensure the protection of the rights and freedoms of data subjects during the processing of their personal data; and to ensure protection against unauthorized access and unlawful dissemination of personal data processed in the Agency’s information systems.

1.4. The provisions of the Policy apply to information that the Agency receives about a data subject in the course of its activities, the provision of services, or the performance of contractual obligations.

1.5. The provisions of the Policy apply to all Agency employees who process personal data, as well as to all other persons (contractors, auditors, etc.) granted access to personal data processing.

1.6. The Policy has been developed in accordance with the following regulatory documents:

  • The Constitution of the Russian Federation;
  • The Labor Code of the Russian Federation;
  • The Civil Code of the Russian Federation;
  • Federal Law No. 149-FZ “On Information, Information Technologies and Information Protection” dated July 27, 2006;
  • Federal Law No. 152-FZ “On Personal Data” dated July 27, 2006;
  • Decree of the Government of the Russian Federation No. 1119 dated November 1, 2012, “On Approval of Requirements for the Protection of Personal Data during Processing in Personal Data Information Systems”;
  • Decree of the Government of the Russian Federation No. 687 dated September 15, 2008, “On Approval of the Regulation on the Specifics of Processing Personal Data Carried Out Without the Use of Automation Tools”;
  • Order of the Federal Service for Technical and Export Control (FSTEC) of Russia No. 21 dated February 18, 2013, “On Approval of the Composition and Content of Organizational and Technical Measures to Ensure the Security of Personal Data during Processing in Personal Data Information Systems.”

1.7. Terms and definitions used in the Policy:

Personal data (PD) – any information relating to a directly or indirectly identified or identifiable natural person (data subject).

Data subject – a natural person who is directly or indirectly identified or identifiable by means of personal data.

Operator – ANO “Innovation Agency,” which independently or jointly with other persons organizes and/or carries out the processing of personal data, and determines the purposes of processing, the composition of personal data to be processed, and the actions (operations) performed with personal data.

Processing of personal data – any action (operation) or set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (dissemination, provision, access), depersonalization, blocking, deletion, and destruction of personal data.

Automated processing of personal data – processing of personal data using computing equipment.

Dissemination of personal data – actions aimed at disclosing personal data to an indefinite group of persons.

Provision of personal data – actions aimed at disclosing personal data to a specific person or a specific group of persons.

Blocking of personal data – temporary suspension of processing of personal data (except in cases where processing is necessary to clarify the data).

Destruction of personal data – actions as a result of which it becomes impossible to restore the content of personal data in a personal data information system and/or as a result of which the physical media containing personal data are destroyed.

Depersonalization of personal data – actions as a result of which it becomes impossible to determine the ownership of personal data by a specific data subject without the use of additional information.

Personal data information system – a set of personal data contained in databases, and the information technologies and technical means ensuring their processing.

Cross-border transfer of personal data – transfer of personal data to the territory of a foreign state to a foreign public authority, foreign natural person, or foreign legal entity.

1.8. The Agency processes personal data in compliance with the principles established by Federal Law No. 152-FZ “On Personal Data” dated July 27, 2006:

  • processing of personal data is carried out on a lawful and fair basis;
  • processing of personal data is limited to the achievement of specific, predetermined, and legitimate purposes. Processing of personal data incompatible with the purposes of its collection is not permitted;
  • the merging of databases containing personal data processed for incompatible purposes is not permitted;
  • only personal data that meets the purposes of its processing is subject to processing;
  • the content and scope of the personal data processed corresponds to the stated purposes of processing. The personal data processed is not excessive in relation to the stated purposes of its processing;
  • during the processing of personal data, the Agency ensures the accuracy of the data, its sufficiency, and, where necessary, its relevance to the purposes of processing. The Agency takes the necessary measures to delete or clarify incomplete or inaccurate data;
  • the storage of personal data is carried out in a form that allows the data subject to be identified for no longer than is required by the purposes of processing, unless the storage period is established by federal law or by an agreement to which the data subject is a party, beneficiary, or guarantor;
  • personal data processed is subject to destruction or depersonalization upon achievement of the purposes of processing or in the event that the need to achieve such purposes is lost, unless otherwise provided by the legislation of the Russian Federation.

1.9. The Agency processes personal data in the following cases:

  • where the data subject has given consent, unless otherwise provided by the legislation of the Russian Federation;
  • where it is necessary to achieve purposes provided for by the regulatory legal acts of the Russian Federation, in order for the Agency to exercise and perform the functions, powers, and duties assigned to it by the legislation of the Russian Federation;
  • where processing of personal data is necessary for the performance of a contract to which the data subject is a party, beneficiary, or guarantor, as well as for concluding a contract at the initiative of the data subject or a contract under which the data subject will be a beneficiary or guarantor;
  • where processing of personal data is necessary for the execution of a judicial act, an act of another body or official, subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings;
  • where processing of personal data is necessary to protect the life, health, or other vital interests of the data subject, if obtaining the consent of the data subject is impossible;
  • where it is necessary to exercise the rights and legitimate interests of the Agency or third parties, or to achieve socially significant purposes, provided that the rights and freedoms of the data subject are not violated;
  • where mandatory disclosure and publication of personal data is required in accordance with the legislation of the Russian Federation.

1.10. The personal data processed by the Agency constitutes confidential information subject to strict protection.

1.11. The Agency publishes the Policy in open access, posting it on the Agency’s official websites at: https://sibnoc.ru, https://schoolcommunication.getcourse.ru, https://cdo.sibnoc.ru, https://export72.ru, https://rck72.ru, https://чкфорум.рф (chforum.rf).

2. Legal Grounds for Processing Personal Data

The legal grounds for the Agency’s processing of personal data are:

  • The Constitution of the Russian Federation;
  • The Civil Code of the Russian Federation;
  • The Labor Code of the Russian Federation;
  • The Tax Code of the Russian Federation;
  • Federal Law No. 7-FZ “On Non-Profit Organizations” dated January 12, 1996;
  • Federal Law No. 402-FZ “On Accounting” dated December 6, 2011;
  • Federal Law No. 167-FZ “On Mandatory Pension Insurance in the Russian Federation” dated December 15, 2001;
  • Federal Law No. 75-FZ “On Non-State Pension Funds” dated May 7, 1998;
  • Federal Law No. 255-FZ “On Mandatory Social Insurance in Case of Temporary Disability and in Connection with Maternity” dated December 29, 2006;
  • Federal Law No. 27-FZ “On Individual (Personified) Records in the Mandatory Pension Insurance System” dated April 1, 1996;
  • Federal Law No. 125-FZ “On Mandatory Social Insurance against Industrial Accidents and Occupational Diseases” dated July 24, 1998;
  • Federal Law No. 165-FZ “On the Fundamentals of Mandatory Social Insurance” dated July 16, 1999;
  • Federal Law No. 178-FZ “On State Social Assistance” dated July 17, 1999;
  • Federal Law No. 166-FZ “On State Pension Provision in the Russian Federation” dated December 15, 2001;
  • Federal Law No. 173-FZ “On Labor Pensions in the Russian Federation” dated December 17, 2001;
  • Federal Law No. 326-FZ “On Mandatory Medical Insurance in the Russian Federation” dated November 29, 2010;
  • Federal Law No. 400-FZ “On Insurance Pensions” dated December 28, 2013;
  • Decree of the Government of the Russian Federation No. 719 dated November 27, 2006, “On Approval of the Regulation on Military Registration”;
  • Federal Law No. 53-FZ “On Military Duty and Military Service” dated March 28, 1998;
  • Federal Law No. 273-FZ “On Education in the Russian Federation” dated December 29, 2012;
  • Order of the Ministry of Education and Science of the Russian Federation No. 499 dated July 1, 2013, “On Approval of the Procedure for the Organization and Implementation of Educational Activities under Additional Professional Programs”;
  • Decree of the Government of the Russian Federation No. 825 dated May 31, 2021, “On the Federal Information System ‘Federal Register of Information on Documents on Education and/or Qualification, Documents on Training'”;
  • Decree of the Government of the Russian Federation No. 1441 dated September 15, 2020, “On Approval of the Rules for the Provision of Paid Educational Services”;
  • Decree of the Government of the Russian Federation No. 537 dated April 30, 2019, “On Measures of State Support for World-Class Research and Educational Centers Based on the Integration of Higher Education Institutions and Research Organizations and Their Cooperation with Organizations Operating in the Real Sector of the Economy”;
  • Federal Law No. 209-FZ “On the Development of Small and Medium-Sized Enterprises in the Russian Federation” dated July 24, 2007;
  • Order of the Ministry of Economic Development of Russia No. 142 dated March 26, 2021, “On Approval of Requirements for the Implementation of Measures Carried Out by the Constituent Entities of the Russian Federation, whose Budgets Receive Subsidies for State Support of Small and Medium-Sized Enterprises, as well as Individuals Applying the Special Tax Regime ‘Professional Income Tax’, in the Constituent Entities of the Russian Federation, Aimed at Achieving the Goals, Indicators and Results of Regional Projects that Ensure the Achievement of the Goals, Indicators and Results of Federal Projects Included in the National Project ‘Small and Medium-Sized Enterprises and Support for Individual Entrepreneurial Initiative’, and Requirements for Organizations Forming the Infrastructure for Supporting Small and Medium-Sized Enterprises”;
  • Order of the Ministry of Economic Development of the Russian Federation No. 77 dated February 18, 2021, “On Approval of Requirements for the Implementation of Measures for the Creation and/or Development of Export Support Centers, Carried Out by the Constituent Entities of the Russian Federation, whose Budgets Receive Subsidies for State Support of Small and Medium-Sized Enterprises, as well as Individuals Applying the Special Tax Regime ‘Professional Income Tax’, in the Constituent Entities of the Russian Federation, in Order to Achieve the Goals, Indicators and Results of Regional Projects that Ensure the Achievement of the Goals, Indicators and Results of the Federal Project ‘Acceleration of Small and Medium-Sized Enterprises'”;
  • Law of the Tyumen Region No. 544 dated February 21, 2007, “On Scientific, Scientific-Technical and Innovation Activities in the Tyumen Region”;
  • Decree of the State Statistics Committee of the Russian Federation No. 1 dated January 5, 2004, “On Approval of Unified Forms of Primary Accounting Documentation for Labor Records and Its Compensation”;
  • Decree of the Government of the Tyumen Region No. 675-p dated December 25, 2017, “On Approval of the State Program of the Tyumen Region ‘Improving the Competitiveness of the Economy'”;
  • Decree of the Government of the Tyumen Region No. 511-p dated December 14, 2018, “On Approval of the State Program of the Tyumen Region ‘Development of Small and Medium-Sized Enterprises and the Scientific-Innovation Sector'”;
  • Order of the Government of the Tyumen Region No. 180-rp dated March 6, 2017, “On Approval of the Regulations for Supporting Innovation Projects Implemented and/or Planned for Implementation in the Tyumen Region”;
  • The Agency’s Charter;
  • Agreements concluded between the Agency and data subjects;
  • Consents of the data subject or their legal representative to the processing of personal data.

3. Purposes of Processing Personal Data, Categories of Data Subjects, and Categories of Personal Data

3.1. The Agency’s processing of personal data is limited to the achievement of the purposes specified in Clause 3.2 of the Policy. The Agency does not process personal data that is incompatible with the purposes of processing.

3.2. The Agency processes the personal data of data subjects for the following purposes:

3.2.1. Purposes of processing the personal data of employees (persons who have entered into an employment contract with the Agency):

  • maintaining personnel and accounting records;
  • ensuring compliance with the labor legislation of the Russian Federation;
  • ensuring compliance with the tax legislation of the Russian Federation;
  • ensuring compliance with the pension legislation of the Russian Federation.

Note: This is an English translation of the original Russian-language document provided by the user. The translation is provided for informational purposes; the original Russian text remains the authoritative version.

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