The SWP's privacy policy for addresses

[Art. 13 GDPR Information to be provided where personal data are collected from the data subject]

[Art. 14 GDPR Information to be provided where personal data have not been obtained from the data subject]

Last updated: 01/2020

Thank you for your interest in the SWP's work and research.

We attach great importance to the protection of your data and your privacy. To ensure that you are fully informed about the collection, processing and use of personal data, please read the following information.

1. Person responsible for the processing of personal data

Your data will be processed in the name and on behalf of:
Stiftung Wissenschaft und Politik (SWP)
German Institute for International and Security Affairs
Ludwigkirchplatz 3–4
10719 Berlin
Tel: +49 30 88007 – 0
e-mail: info(at)swp-berlin.org

Chairman of the Executive Board: Prof. Dr. Volker Perthes

If you have any questions about data protection at the SWP, you can contact our data protection officer at any time:

2. Data protection officer

You can contact our data protection officer as follows:
Datenschutzbeauftragte der
Stiftung Wissenschaft und Politik (SWP)

German Institute for International and Security Affairs
Ludwigkirchplatz 3–4
10719 Berlin
Germany
e-mail: datenschutz(at)swp-berlin.org

3. Further information on the processing of your data

We store the following categories of data in our address database:

  • Name, title without ranks, address data (usually business addresses incl. employer), tel./FAX, email; position/-departmental affiliation
  • Usage data / delivery data: publications, information products and invitations received (including passing on to cooperation partners for the purpose of the invitation); distribution keywords
  • Data concerning predecessor – successor
  • Wishes and preferences, where applicable (e.g. shipping method; topics)

4. Purpose of the processing

We collect and process your personal data for the following purpose:

  • Disseminating the SWP's research and information products, such as press and online media reviews (Pressespiegel and WebMonitor), and enabling academic exchange (including invitations to events and the provision of appropriate  address data to cooperation partners for events organized by the SWP and third parties where the invitations are issued by the partner)
  • Providing contact data and other information on individuals for the entire research and consulting process
  • Preventing unwanted delivery or dissemination in case of objection
  • Proving consent and documenting transfers.


Your data will not be used for automated decision making or profiling.

5. Legal basis for processing and duration of data storage

a) Consent

If we have received your data with your consent, the legal basis for the processing of your data is your consent pursuant to Art. 6 para. 1 subpara. 1 a) GDPR.

Your data will be stored for as long as your consent is valid.

After this, the data are deleted, unless further data processing is necessary for the SWP's work and a legal basis exists. One such exception is in particular: we store your consent until 31 March of the fourth calendar year after the deletion of your data exclusively for the purpose of being able to prove your consent. The legal basis for this is Art. 6 para. 1 subpara. 1 c) in conjunction with Art. 5 para. 2 GDPR, Art. 7 para. 1 GDPR and Art. 24 para. 1 GDPR as well as Art. 6 para. 1 subpara. 1 f) GDPR. The legitimate interest in processing on the basis of Art. 6 para. 1 subpara. 1 f) GDPR is proving your consent, i.e. as defence against legal claims.

You have the right to withdraw your consent at any time, without prejudice to the lawfulness of the processing carried out on the basis of the consent up to the point of withdrawal or processing carried out on another legal basis.

b) Balancing of interests

If we have received your data not directly from you, but on the recommendation of third parties or via publicly accessible sources, or from you, but without your express consent, the legal basis for processing your data is Art. 6 para. 1 subpara. 1 f) GDPR. The legitimate interest for processing your data for active use by the SWP and, if necessary, by the partners of cooperation events is fulfilling the statutory purpose of the SWP, namely conducting and, where appropriate, publishing of academic studies on international relations as well as foreign and security policy with the aim of providing policy advice on the basis of independent academic research, when passing on to partners of cooperation events, also their interest in fulfilling their tasks.

Therefore, our researchers need information about political and social actors, and our distribution management needs to process the data to ensure that our publications reach and supply suitable addressees for specific target groups. In case SWP organises an event in cooperation with an external partner, SWP shares with this external partner relevant data on political and social actors who may be invited to the event. We conclude agreements with our cooperation partners that oblige them to use these data only for this purpose, and to delete them afterwards unless you agree with the cooperation partner that they may further process your data.

Your data will be processed by us for as long as they are needed to fulfil these purposes. The data will then be deleted. The SWP constantly updates stored data and checks each time whether they are still necessary for its work. With the end of your political or social activity, the necessity for processing usually no longer exists, and the data are deleted. However, actors do not usually start another activity that is also relevant to the SWP immediately after the end of the previous activity, but only after a certain delay, or at least the SWP usually only becomes aware of this after a delay. Therefore, it will be decided on a case-by-case basis whether an individual’s data are deleted immediately after the end of their previous activity or whether the data record is provisionally deactivated. Inactive data records will be deleted after one year at the latest if they have not been reactivated due to new information. Each data set shall be re¬viewed after three years at the latest to assess the need for continued storage.

If a person is stored as a predecessor or successor of another individual, this infor¬mation will be deleted either if the other individual’s data are deleted or if it is determined during verification of the other individual’s data that the information on the predecessor or successor is no longer required.

If you raise a legitimate objection to the processing of your data, we will either block your data record so that we no longer send you any information, or include in a block list those of your data that we need in order to clearly identify you and delete the remaining data. This applies in any case if you object merely to receiving our information. With¬out such a blacklist, we might add you to one of our mailing lists in the future if we received your data again. However, we will contact you if your statement is not clear to us. If you tell us that you do not wish to receive any further information from us, we will respect this wish in any case, regardless of whether you are legally entitled to it. The legal basis for processing your data in the blacklist is Art. 6 para. 1 subpara. 1 f) GDPR. The legitimate interest in pro-cessing your data is to comply optimally with your objection and to avoid un¬solicited submissions of our publications. Your data will be stored in the blocking list until you request deletion, i.e. also object to their storage in the blocking list, or until there is no risk of you being added to the mailing list again against your will. This will regularly be the case when you finally cease any political or social activity that is relevant to the work of the SWP. Such a check shall take place at least every five years for data on the blacklist.

Where your data are passed on to a cooperation partner for the purpose of inviting you to a cooperation event, we store this transfer for documentation purposes for as long as we store your data. The legal basis for this is Art. 6 (1) (1) (c) in conjunction with (c). Art. 15 para. 1 letter c GDPR and Art. 24 para. 1 GDPR as well as Art. 6 para. 1 subpara. 1 letter f GDPR. The legitimate interest in processing on the basis of Art. 6 para. 1 para. 1 letter f GDPR is being able to fulfil your requests for information according to Art. 15 GDPR.

6. Recipient of your data, data exports

Our distribution management and our administrators have access to your data. Where required, our researchers have access to certain extracts from our database that are necessary for their specific work, including where necessary the legal department.

At certain events organised by the SWP in cooperation with a partner, the cooperation partner also issues invitations to the event on behalf of the SWP. In these cases, the SWP transfer to the cooperation partner contact data of selected individuals who should, from its perspective, be invited to the event. We conclude agreements with our cooperation partners that oblige them to use the data received from us only for these purposes and to delete them afterwards, unless you agree with the cooperation partner that the latter may further process your data. Cooperation partners include in particular academic institutions, universities, public institutions, authorities (e.g. the German Foreign Ministry) and foundations, non-governmental organisations and international organisations.

If we send you printed products, we use an order processor who uses your data exclusively for the dispatch of the printed products. The latter is strictly bound by our instructions and may not process or pass on the data for his or her own purposes.

Your data will be processed by us or on our behalf exclusively in Germany.

The only exception is the platform we use for the information product Pressespiegel: Factiva Limited, The News Building, 1 London Bridge Street, SE1 9GF, London („Factiva“). To be able to send you Pressespiegel, we transfer your personal data to Factiva and thus grant Factiva permission to register you. The legal basis for transferring these data is fulfilling our contractual or pre-contractual duties generated by your order of Pressespiegel, Art. 6 para. 1 subpara. 1 letter b GDPR.

Processing as part of the data transfer to Factiva is carried out by us jointly with Factiva, in accordance with Art. 26 GDPR. We have agreed with Factiva a privacy policy regarding rights and duties under this joint responsibility.

Once you are registered on the Factiva platform, you will have access to Factiva’s (Dow Jones’s) privacy policy and cookie policy, which can also be found at:

https://www.dowjones.com/privacy-policy/
https://www.dowjones.com/cookies-policy/

In the agreement on joint responsibility, Factiva has committed to processing personal data only in accordance with the respective data protection legislation and the purposes and guidelines of the privacy and cookie policies, and to fulfil the contract.

We further agreed that Factiva will be available for you to contact regarding the processing of your personal data and that Factiva will answer your questions.

On request, we will be happy to provide you with further essential contents of our agreement. The division of competencies that we have agreed between us does not mean that to exercise your rights, you must contact the person designated as being responsible. You may put all your questions regarding your jointly processed data to any of the designated responsible persons or to our data protection officer at any time and in any form.

Our cooperation partners at events may also come from other countries, so that your data may be transferred to countries outside the EU and the EEA, where the level of data protection may be lower. Adequacy decisions of the European Commission on data protection standards are currently available for Andorra, Argentina, Canada (restricted), Switzerland, Faroe Islands, Guernsey, Israel (restricted), Isle of Man, Jersey, New Zealand and Uruguay as well as the USA within the framework of the "Privacy Shield", provided the recipient is certified accordingly. In all other cases, we conclude standard contractual clauses with the recipient in accordance with the European Commission decision of 27 December 2004. You can look up the text in the Official Journal of the European Union, 29 December 2001, p. L 385/74, and on the Internet at

https://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2004:385:0074:0084:EN:PDF

Upon request, we will send you a copy of the standard contractual clauses.

7. Voluntary provision of your data

The provision of your personal data is not mandatory and is not required for the conclusion of a contract. You are not obliged to provide personal data. However, if you do not provide your e-mail address or mailing address, you may not receive our information by e-mail or post.

8. Your rights

Under the General Data Protection Regulation you have

  • the right to information free of charge,
  • the right to rectify or delete or limit data processing,
  • the right to object to processing,
  • a right to data transferability.


Where data processing is based on consent, you have the right to withdraw your consent at any time, without prejudice to the lawfulness of the processing carried out on the basis of the consent up to the point of withdrawal or the processing carried out on another legal basis.

If our processing of your personal data for our database is based on Art. 6 para. 1 subpara. 1 letter e or f GDPR, i.e. if you have not given consent, you have the right to object to the processing in accordance with Art. 21 GDPR. If you object for reasons arising from your particular circumstances, we will no longer process your personal data, unless we can prove compelling reasons for processing that qualify for protection and supersede your interests and rights, or unless the processing serves to assert, exercise or defend legal claims.

You also have the right to complain to a data protection supervisory authority about our processing of your personal data, for example to the supervisory authority responsible for us:

Berliner Beauftragte für Datenschutz und Informationsfreiheit,
Friedrichstraße 219,
10969 Berlin,
Germany,
Phone +43 30 138890,
Fax +43 30 2155050,
e-mail mailbox(at)datenschutz-berlin.de.

If you have any questions or requests regarding data protection, you can contact our data protection officer at any time: datenschutz(at)swp-berlin.org.