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Privacy policy

Privacy policy and personal data protection in the e-JN information system

I.    Basic data on processing of personal data (article 13 of General Data Protection Regulation)
II.   Validity of the Privacy Policy
III. Types of personal data
IV.   Manner of safekeeping
V.    Web cookies

I. Basic data on processing of personal data (article 13 of General Data Protection Regulation)

The controller of personal data:

Ministry of Public Administration, Tržaška cesta 21, 1000 Ljubljana, e-mail address: gp.mju@gov.si.

Contact information on the caretaker of the personal data filing system and the Data Protection Officer (hereinafter: DPO) within the Ministry of Public Administration:

caretaker of the filing system: gp.mju@gov.si
DPO: dpo.mju@gov.si.

The processor of personal data:

For the purpose of technical maintenance of the e-JN information system on the basis of a public procurement procedure a contract is concluded with SRC sistemske integracije d.o.o., Tržaška cesta 116, p.p. 2988, 1001 Ljubljana, src@src.si, who is the processor for the Ministry of Public Administration.

Joint controller of personal data:

In documents uploaded to the e-JN information system by the users (tender, supplementation, etc.) some personal data may be stated, for example data on the statutory representative, employees, third persons. Ministry of Public Administration and each individual user, in the name of the entity for which he uses the e-JN information system, concluded a Joint Controller Agreement by concluding the General Terms and Conditions for the use of the e-JN information system (article 26 of the General Data Protection Regulation). Each contracting authority and each economic operator therefore present joint controllers of personal data exchanged through the e-JN information system.

Information on the existence of rights:

Users have the right to demand access to their personal data and the rights to rectification, erasure and restriction of processing and the right to object the data processing, in so far as their wish is not in contrast with the operation of the e-JN information system.

Users can demand their rights with the caretaker of the filing system within the Ministry of Public Administration or with the caretaker of the filing system within each individual contracting authority/economic operator.

If his claim for personal data protection is not successful, he can turn to the DPO within Ministry of Public Administration.

Information on the existence of automated decision-making, including profiling:

Ministry of Public Administration does not execute automated decision making on the basis of profiling with personal data.

Information on the right to appeal:

A possible appeal may be filed with the Information Commissioner, Dunajska 22, 1000 Ljubljana, e-address: gp.ip@ip-rs.si, phone: 012309730, web page: www.ip-rs.si).

The purpose and legal basis for the processing of personal data:

Data on registered users of the e-JN information system is processed for the purpose of functioning of the e-JN information system, to verify the identity of the registered user and for enabling that the system is being used by the registered person. The purpose for processing personal data within the e-JN information system is to have information on the users who for the purpose of legal security and the functioning of the e-JN information system must be determinable individuals with provable identities. The basic purpose of the functionality of electronic submission of tenders is the exchange of information and documents in the public procurement procedure. These can include personal data on users or third parties. Ministry does not process that data other than store it in the e-JN information system.

Personal data, contained in the documentation exchanged through the e-JN information system, is needed due to the nature of the system itself. Ministry and its users do not access, verify (on their own initiative) or use data in any way. The data is stored on our servers until deletion.

Through the functionality of verifying in official records (e-Dossier) the following personal data is exchanged between the e-JN information system, the Slovenian Business Register and the Criminal Records: name and surname, national identification number (EMŠO), information on no criminal record: whether the subject fulfils the criteria from the first paragraph of Article 75 of the Public Procurement Act (Official Gazette of the Republic of Slovenia [Uradni list RS], No. 91/15 with changes; hereinafter: ZJN-3) or the first paragraph of Article 32 of the Public Procurement in the Defence and Security Sector Act (Official Gazette of the Republic of Slovenia [Uradni list RS], No. 90/12 with changes; hereinafter: ZJNPOV). The purpose of digital verification and exchange of data is easier, faster and a more secure verification of fulfilment of exclusion grounds in public procurement procedures.

On all visitors of the e-JN webpage, who give an expressed permission, data on their IP address and the visited pages within the e-JN information system are collected. The data is used to discover and fix the flaws in the system.

The legal basis for the processing of personal data on registered users and data, contained in the documentation, are points b) and e) of the first paragraph of Article 6 of the General Data Protection Regulation. Personal Data is processed on the basis of Joint Controller Agreement, concluded with the General Terms and Conditions for the use of the e-JN information system, and on the basis of public interest carried out by the Ministry when administrating the information system. Legal basis for the functionality e-Dossier is point c) of the first paragraph of Article 6 of the General Data Protection Regulation. Legal basis for gathering data on IP address and visited sub-pages is point a) of the first paragraph of Article 6 of the General Data Protection Regulation.

Information on transfers to third countries and international organisations

If the user accepts cookies on e-JN webpage, some data, defined in in Chapter V. of this Privacy Policy, is transferred to United States of America where they are processed via the Google Analytics services.

Data on registered users will not be given to anybody. Data, contained in the documentation, exchanged through the e-JN information system, will be transferred only to addressees, chosen in the e-JN information system by the user who uploaded the documentation (the user of the tenderer who uploads the tender documentation and sends it to the users of the contracting authority through the e-JN information system).

II. Validity of the Privacy Policy

This privacy and personal data protection policy (hereinafter: Privacy Policy) is part of the General Terms and Conditions for the use of the e-JN information system (hereinafter: General Terms and Conditions). Through this Privacy Policy the Ministry of Public Administration as the administrator of the e-JN information system, undertakes to ensure that your personal and other data submitted into the system will be carefully protected, in accordance with the valid regulations, General Terms and Conditions and this Privacy Policy.

This Privacy Policy is valid from 6 March 2023 onwards.

III. Types of personal data

The e-JN information system keeps the following personal data:

a. general data on user account

Data will be stored in the record of registered users of the e-JN information system, and will be used exclusively for the needs of the operation of the e-JN information system and to ensure that the registered person uses the information system.

To this end the following data are kept: name and surname of user, employer or organization in which name the user uses the system, e-mail address, telephone number, registration and VAT number, the list of user rights in the e-JN information system.

Users’ personal data will be stored for a maximum of five years from their last login to the e-JN information system.

b. information communicated together with documentation the user uploaded to the e-JN information system

Documents that users upload to the e-JN information system may contain personal data of e.g. a statutory representative, employees, third parties.

The ministry will not scrutinise the personal data uploaded in this way to the e-JN information system or use it for any purpose other than storage. In storing data, all the prescribed procedures and measures for the protection of personal data are used.

Documents will be stored in the e-JN information system for a maximum of six months from the conclusion of the procedure in the e-JN information system.

IMPORTANT:

In submitting personal data in documents users upload to the e-JN information system, they themselves are responsible for acting in accordance with the regulations governing personal data protection. They may submit into the e-JN information system only those data which they have the right to submit, and which they may use only in the manner laid down in the regulations governing personal data protection. Only submit data into the e-JN information system that is required for the execution of the public procurement procedure.

In the public procurement procedure, the contracting authority may process the personal data of individuals wherever this is necessary for conducting the public procurement procedure and executing a contract with them, if the processing of personal data is necessary and appropriate for conducting the procedure or for contract fulfilment. The contracting authority keeps data and processes them with due diligence, and archives them together with documentation on the public procurement procedure.

c. data, processed through the functionality of verifying in official records (e-Dossier)

Legal basis for the e-Dossier verification functionality represents Article 77 of ZJN-3 and Article 31 of ZJNPOV in accordance with Article 250.b of Enforcement of Criminal Sanctions Act (Official Gazette of the Republic of Slovenia [Uradni list RS], No. 110/06 with changes).

Personal data, exchanged through the e-Dossier verification functionality, are available to the authorised representative of a contracting authority only once, they are not stored in the e-JN information system and cannot be re-opened. The e-JN information system for the reason of keeping the audit trail of personal data processing, stores only the information who and in the name of which contracting authority sent the verification request, when he sent the request and received an answer.

d. data on IP address and the visited pages within the e-JN information system

On all visitors of the e-JN webpage, who give an expressed permission, data on their IP address and the visited pages within the e-JN information system are collected.

The data is collected using web cookies (more on this in chapter V. Web Cookies).

The data is stored for 26 months with the intent of web analytics.

IV. Manner of safekeeping

Users access the e-JN information system through a secure connection, which ensures the protection of privacy and of any data submitted. All communication between the registered users and the e-JN information system is encrypted.

All the prescribed procedures and measures to protect personal data and prevent unauthorised processing of such data are in place, thereby ensuring:

the security of premises, equipment and system software,
protection of the application software used to process personal data,
prevention of unauthorised access to personal data during their transfer (including via telecommunication channels and networks),
subsequent identification when the specific data were used or entered in the personal data filing system, and who performed these actions,
conclusion of data Processing Agreement with the current processor who offers technical maintenance of the system,
all known security risks in the information system are promptly fixed,
the use of the clean desk and desktop policy.

Exclusively for the purpose of keeping users informed, from time to time they may receive informational notices related to their obligations under public procurement legislation to the e-mail address they provided upon registration. The information in such notifications is of an informative nature.

V. Web cookies

What are cookies?

The e-JN information system uses cookies, i.e. small text files on the user’s computer that store information on how many times you visit the e-JN website and what you do on the site. Cookies are not used for your identification. They are here only to provide better activity of the e-JN information system. You can edit or delete cookies as you wish. Cookies are used to record website statistics, in order to more easily detect and eliminate possible errors in the functioning of the e-JN information system. We use Google Analytics services that enable us to track user’s movement on our web page.

Google Analytics

On the e-JN information system web page data on visitors are gathered using the Google Analytics services. Google Analytics is a web tool by the Google company. The data on visitors of the web page, that is stored in cookies, is transferred and stored by the Google company, also on servers in the United States of America (hereinafter: USA).

Google Analytics stores information on which pages in the e-JN information system you visit, how long you stay there, how did you reach them and what will you do on the e-JN information system web page next. We concluded a Data Processing Agreement with the Google company and we do not allow Google to use or share our analytical data.

Transfer to the Google company, to the USA, is admissible because the USA are listed on the register of third countries, for which the Information Commissioner of the Republic of Slovenia determined to have a suitable manner of personal data protection concerning the transfer of data; for the USA, to the companies registered in the EU-USA Privacy Shield. The Google company is an active participant of the EU-USA Privacy Shield.

Name of cookie	Purpose	Duration	Origin
_utma	Page view statistics	2 years	Google Analytics
_utmt	Page view statistics	10 minutes	Google Analytics
_utmb	Page view statistics	30 minutes	Google Analytics
_utmc	Page view statistics	Until browser is closed	Google Analytics
_utmz	Page view statistics	6 months	Google Analytics
_utmv	Page view statistics	2 years	Google Analytics