Privacy Policy: Layperson-Oriented Mediation Application FB56

1. Preamble and

Scope of Application: In addition to the General Privacy Notice regarding the use of our onlineservices, we would like to inform you here about the specific processing of your personal data as well as the data of the local contact persons you have designated as part of the online application process for the placement of volunteer lay language mediators by the City of Aachen.

2. Purpose of Data Processing

Data is collected and processed for the following specific purposes:

• Processing of the referral request: Receipt, review of form and content, and administrative processing of the referral request for the deployment of volunteer language interpreters.
• Assignment Coordination and Needs-Based Placement: Careful selection of a suitable language mediator based on the requested language skills, the specified appointment time, and objectively justified gender-specific preferences.
• On-site Mission Coordination: Transmission of the basic information required to carry out the mission (date, time, exact location, incident category) as well as the contact information of the on-site contact person to the assigned language mediator.
• Communication and Coordination: Contacting the applicant and/or the designated on-site contact person to address any questions and provide status updates on the placement process.

• Quality Assurance, Evaluation, and Statistics: Anonymized and aggregated analysis of case numbers and language needs to guide the needs-based further development of the services offered by the City of Aachen’s Municipal Integration Center.
  
  

3. Legal Basis for Processing

The processing of your personal data and the data of the designated contact person is based on the following legal grounds:

• Performance of a task carried out in the public interest (Art. 6(1)(e) of the GDPR in conjunction with § 3 of the DSG NRW): To carry out the task in the public interest undertaken by the City of Aachen as part of its municipal integration support efforts and to ensure low-threshold access to language mediation services.
• Contract Preparation and Performance (Art. 6(1)(b) of the GDPR): To the extent that data processing is necessary for the establishment, organizational management, and fulfillment of the brokerage relationship.

• Legal obligation (Art. 6(1)(c) of the GDPR): To comply with legal requirements applicable to the City of Aachen, in particular documentation and retention obligations under budgetary, municipal, and auditing laws.

4. Categories of Data Processed

As part of the online application process, the following categories of data, in particular, are collected and processed:

• Information about the applying institution and individual: Name of the applying institution; last name, first name, work email address, and work phone number of the applicant.
• Assignment and Request Details: Required language(s), assignment date, time, estimated duration, selected incident category, assignment location (street, house number, ZIP code, city, exact on-site meeting point), and—if applicable—a request for a specific gender of the language interpreter, supported by a valid reason.
• Contact information for the on-site representative: Last name, first name, work phone number, and work email address.
• Legal Disclaimers and Log Data: Documentation of authorizations to act on behalf of the institution, confidentiality obligations regarding the contact information of language mediators, acknowledgment of the exclusion of legal effect/professional interpreting services, and confirmation of the organizational framework.

• Exclusion of Special Categories of Personal Data (Art. 9 GDPR): Special categories of personal data pursuant to Art. 9(1) of the GDPR (such as health data, medical diagnoses, religious affiliation, or reasons for fleeing) are strictly excluded from collection and must not be entered in the free-text fields (“Comments,” “Additional Information”) must not be entered.

5. Recipients or Categories of Recipients of the Data

Within the Aachen City Administration and to external recipients, personal data is transmitted exclusively within the scope of statutory authority and strictly for specific purposes:

• Aachen Municipal Integration Center: The specialized and coordinating office within the city administration responsible for administrative processing, review, and placement.
• Assigned volunteer lay language mediators: Earmarked sharing of the basic information required to carry out the specific assignment (assignment date, time, exact location/meeting point, language, type of event, and the name and contact information of the on-site contact person).
• Requesting municipal departments or schools: Provided that the request is submitted by a municipal agency and the transmission is necessary for internal processing and coordination.
• IT Service Provider (Data Processor): regio iT GmbH (Aachen) acts as the technical service provider for the hosting, operation, and maintenance of the online form system based on a data processing agreement in accordance with Article 28 of the GDPR.

• Audit and Oversight Authorities: The Audit Office of the City of Aachen and the government data protection officer, within the scope of their statutory audit, inspection, and oversight duties.

6. Duration of Storage and Retention Periods

Personal data will be stored only for as long as is necessary to fulfill the respective processing purposes or as required by statutory retention obligations:

• In the online form system (technical cache): The data entered in the online application is automatically deleted from the technical cache of the online form system (regio iT GmbH) no later than 6 months after successful submission.
• In the specialized procedure (Municipal Integration Center):
  • Successful placements: After the assignment is completed, the application data is retained for a period of 2 years (counting from the end of the calendar year in which the assignment took place) to ensure quality assurance, maintain records, and facilitate proper billing, and is subsequently deleted.
  • Requests that were not fulfilled or were canceled: Data related to requests that were canceled or not fulfilled due to lack of capacity will be deleted from the specialized system no later than 6 months after the cancellation or the expiration of the requested service date.

• Retention Requirements Under Budget and Archival Laws: If application documents or files are relevant for auditing or as supporting documentation, they are retained for up to 10 years in accordance with the municipal budgetary, financial, and archival regulations of the State of North Rhine-Westphalia before being deleted or destroyed.

7. Provision of Data and Obligations to Cooperate

Providing your personal data is necessary for the proper processing of your application and the completion of the placement:

• Required Information: To process, review, and organize the placement application, it is mandatory to provide the name of the applying institution, the name of the applicant, the specific details of the assignment, and the contact information of the on-site contact person.
• Marking of Required Fields: In the online form, all information that is absolutely necessary for processing is marked as required fields (indicated by an asterisk “*”). Voluntary information (such as a specific on-site meeting place or a gender-specific preference) is explicitly marked as optional.
• Consequences of Failure to Provide Information: If you do not provide the information marked as required fields, your referral request cannot be processed, and consequently, no volunteer language mediator can be coordinated or assigned.

• Obligation to Provide Information in the Case of Collection from Third Parties (Art. 14 of the GDPR): If you designate a local contact person other than yourself in the form, you are required to inform that person in advance that their work contact information will be transmitted to the City of Aachen as part of this process.