Data Protection Policy

SWEDISH Vipassana ASSOCIATION (FÖRENINGEN VIPASSANA SVERIGE)

The purpose of this document is to inform about the collection, storage and viewing of personal data in connection with Vipassana Meditation courses arranged by the Swedish Vipassana Association (The Association).

This policy consists of two parts. The first part gives general information about data processing in relation to the application and registration procedure for a Vipassana course, and in relation to the use of the Swedish Vipassana websites. The second part informs in more detail about how data is processed and by whom in relation to a Vipassana course. Personal data means any data that can be linked to an individual person.

The controller and processor of the data is The Swedish Vipassana Association, registration number 802410-2710, Lyckebygården, 599 93 Ödeshög, Sweden.


A. GENERAL INFORMATION

The information we collect
If you choose to register for a Vipassana Meditation course via our online or conventional registration application, the types of personally identifiable information that may be collected include: name, address, e-mail, telephone number, fax number, and all the other highly personal information that is called for on the application form and on the course registration form that you fill out when arriving to the centre. Your personal information contained in your course application and registration forms are stored in a secure manner by the Association and the only persons having access thereto are those who have a specific “need to know”, such as the course registrar, the centre manager and the assistant teacher(s) conducting the course to which you seek admission.

How We Use Your Information
We use the information you provide about yourself in your application and registration forms to evaluate your application for admission to a course and to register you for that course. In some cases we may use your name, postal address and/or email address to send you information about Vipassana related activities and facilities, if you have not opted-out of such contact. The Association does not ever make your personally identifiable information available to third parties, for commercial or any other reason. We do not disclose your personal information outside of the facilities of our affiliated organisations and their common infrastructure except when required to do so by law, for example, in response to a court order or subpoena. We may also disclose such information in response to a law enforcement agency's request.

All teachers and assistant teachers of Vipassana as well as all meditation centre staff and servers only have access to your information submitted on the course application and registration forms on a "need to know" basis. Such information is maintained in confidence and safeguarded against disclosure to or access by third parties once it reaches the centre or the course registrar to which it is submitted. The only risk of inadvertent disclosure of your information can be in the case of applications submitted by e-mail and that is while the information is being sent over the open Internet, as under some circumstances our e-mail application facilities are not secure. Please do not use the e-mail application facility on this website unless you are prepared to personally take this risk.

Rights of Access of Students and Servers to their own Data
Someone who believes that the centre has stored information that he/she has provided may view a copy of that information, if it actually exists. Such a person must provide the Registrar with his/her name and the dates of the course which he/she applied for in writing, together with a copy of suitable identification (for example a drivers license.) The copy of the data may be picked up after one month from the date of the request, upon production of the identification document.

Someone who wishes to correct data regarding him/herself which is held by the Registrar must provide a copy of the data as currently held (obtained as described above) and a written request containing the changes, together with identification. The decision as to whether to accept the change or not will be made by an Assistant Teacher and conveyed to the applicant within a period of one month. If the changes are not accepted then the reasons for non-acceptance will be given.

Removal from database
The Association will use data stored in our database to send out newsletters and possibly other information about Vipassana activities a couple of times a year. If you want to have your name or other personally identifiable information removed from our database, you can do so by sending an e-mail to us at info@sobhana.dhamma.org. This means that you will not receive newsletters and other information from the Association.

Notes taken by Assistant Teachers
In rare cases, the Assistant Teacher(s) may process notes referring to students on a list. Such a list can be kept electronically or manually. The data is kept strictly confidentially and will be accessible only to Assistant Teachers and to limited extent Registrars. The purpose of sharing these notes is to enable other Assistant Teachers to support students on future courses, and in rare cases restricting students from attending future courses. The notes may in rare cases include information on health and medication. Such notes are only to be processed when it is absolutely necessary and should not be kept for longer than required. The notes will not include sensitive data unless the student has consented to this, for example by signing the registration form.
The electronic list of notes will be maintained by a listmaster, who is appointed to fulfil this task by responsible teachers in this tradition.

Each Assistant Teacher is responsible for the entries that they make and shall be regarded as the owner of that data.

How to Contact Us
If you have any questions or concerns about the privacy or any other policies of the Vipassana website or its implementation you may contact us at info@sobhana.dhamma.org


B. HOW AND BY WHOM THE DATA IS PROCESSED

The following information is given to describe in more detail how personal data is processed in relation to a Vipassana course.

Data submitted to the Association could be contained in any of the following documents:
1. Students/Servers Application Form
2. Students/Servers Registration Form
3. Medical Questionnaires
4. Practices in Conflict Questionnaires

Purpose of collecting data
Data is collected to enable the Assistant Teacher conducting the course to assess if a student is suitable to be accepted for a course and to enable the registrar to plan accommodation, food and sometimes transport for the student. This also enables proper guidance and assistance to be given to students prior to, during and after a Vipassana course, and provides a record of students who have attended courses offered by the Association.

Collection of Data
The course registrar collects application forms and sometimes Medical Questionnaires or/and Practices in conflict Questionnaires before a student or server is admitted to a course. Data can be submitted electronically or conventionally. Students give information voluntarily.

On the first day of the course, the Course manager collects registration forms from students and servers. The Registrar and Course manager hand over all application and registration forms, including Medical Questionnaires and Practices in conflict Questionnaires, to the Assistant Teacher(s) conducting the course.

Viewing of Data
The Application forms may be read by the Registrar(s), the Assistant Teacher(s) conducting the course or another Assistant Teacher who can give approval for acceptance to a course. A translator may translate the data on this form where necessary. The same applies for Medical Questionnaires and Practices in Conflict Questionnaires.

The outside of a Registration form (i.e. pages 1 and 4) can be read by any old student approved to do so by an Assistant Teacher. This will mostly be the Course manager and the Assistant Teacher(s). The inside of a registration form (i.e. pages 2 and 3) may be read only by an Assistant Teacher. A Registration form may be translated by a translator if necessary.

Reasons for storage
Data are stored to provide a record of the course, to enable help to be given to students in the future (when coming for another course), and for legal reasons.

Storage of Forms and Data
Forms are stored with the registrar until one or two days before the course. During the course the forms are kept in the Assistant Teacher residence with the key only available to the Assistant Teacher(s). At the end of the course forms are put in a locked archive in the centre. Only Assistant Teachers, or at times the Centre Office Manager, acting under instructions from an Assistant Teacher, can access them. They are stored in folders by the date of the course. The forms held by the Association will be destroyed after a period of 10 years.

A summary of the data provided by a student may be made on a computer for easy perusal by the Assistant Teacher or the registrar during the course. This summary of data may be printed on paper and stored in the archive after the course, in accordance with what applies to other stored documents containing personal data. The electronic version of such a summary of data will be deleted after the course. The Association may however keep certain data in its database, such as name, date of birth, gender, address, e-mail address, telephone number, course dates and types of courses that the student has attended.

Instructions given to Registrars regarding the Data
“These forms may contain sensitive data regarding students and servers. The data may not be copied without the permission of an Assistant Teacher. The data may not be given to anyone other than an Assistant Teacher or a Course Manager. To assist with management of the course, some of the data from these forms may be entered into a computer. You may not read pages 2 and 3 of the registration forms. The data may never be used for commercial purposes by the Association or anyone else. Data that students supply may be summarised on a computer.

The registrar must also ensure that all e-mails and electronic files pertaining to students (apart from student’s name, date of birth, gender, address, e-mail address, telephone number and partner’s name in the database) on each course are deleted at the end of each course. These documents may in some cases be printed off and stored with other student forms and then deleted form the computer.


Instructions given to Course Managers regarding the Data
“ These forms may contain sensitive data regarding students and servers. The data may not be copied without the permission of an Assistant Teacher. The data may not be given to anyone other than an Assistant Teacher or a Course Manager. A Course Manager may read only pages 1 and 4 of the Registration Form. Only Assistant Teachers may read pages 2 and 3. You may not read the Application Forms (other than the names, ages and gender), the Medical Questionnaires or the Practices in Conflict Questionnaires. The data may never be used for commercial purposes by the Association or anyone else. The data may be shown to the student who gave the data under certain circumstances. These circumstances are given in the Data Protection Policy.”

Instructions given to Translators regarding the Data
“ These forms may contain sensitive data regarding students and servers. You may only provide a translated version of what is in the forms for use by the Assistant Teacher or Registrar. You must never retain any data yourself or convey any data to anyone other The Assistant Teacher and the Registrar.”

Instructions given to Assistant Teachers regarding the Data
“These forms may contain sensitive data regarding students and servers. The sensitive data such as medical information may not be given to others except in the case of medical emergency or to a lawyer for legal reasons. The non-sensitive information such as address data may be given to others to assist students in their meditation (for example giving the name and address to an authorised newsletter in this tradition). The Assistant Teacher, the Association or anyone else may never use the data for commercial purposes. The data may be shown to the student who gave the data under certain circumstances. These circumstances are given in the Data Protection Policy.

Effective Date
This Privacy Policy is effective as of May 15, 2007. We reserve the right to modify the terms of this policy at any time and in our sole discretion. Your use of the Vipassana website constitutes a binding acceptance of the above-referenced policies.