Policy for the protection of personal data
General information
On May 25, 2018 the European Union enforced a new General Data Protection Regulation. This Regulation aims to guarantee the safety of personal data for natural persons from all EU member states and to unify the rules for the processing of such data.
In its capacity as administrator of personal data Family National Association meets all requirements of this new regulation by collecting personal data in as much as it is necessary for providing its services, and protects it with responsibility and in accordance with the law.
Information about the Administrator of personal data
- Name: Family National Association
- UIC/BULSTAT: 131113627
- Head office and address of management: Sofia, No.4, Vitosha Blvd., floor 5
- Address for correspondence: Sofia, No.4, Vitosha Blvd., floor 5
- E-mail: familyadoption-bg [ad] com; adoptionadoption-bg [ad] com
- Telephone: +35929803083; +3599804106
- Name of employee responsible for the protection of personal data:
Nadezhda Krasimirova Krasteva
- Address for correspondence: Sofia, No.4, Vitosha Blvd., floor 5
- E-mail: familyadoption-bg [ad] com; adoptionadoption-bg [ad] com
- Telephone: +359889669381
Information about the competent supervisory authority
- Name: Commission for Personal Data Protection
- Head office and address of management: 1592 Sofia, No.2, Prof. Tsvetan Lazarov Blvd.
- Address for correspondence: 1592 Sofia, No.2, Prof. Tsvetan Lazarov Blvd.
- Telephone: +35929153518
- E-mail: kzldgovernment [ad] bg; kzldcpdp [ad] bg
- Website: www.cpdp.bg
Family National Association operates in accordance with the Law for Protection of Personal Data and Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data.
Grounds for the collecting, processing and storing of your personal data.
Goals and principles.
Art. 1. (1) Family National Association collects and processes personal data that you provide to us in relation to our intermediary activity in procedures for intercountry adoption, in view of:
- Providing specific information in relation to an inquiry made by you.
- Preparing of contracts and execution of services stated therein.
- Preparing and processing data contained in your dossier with the goal of presenting the Ministry of Justice with detailed information about your approval for the adoption of a child – a Bulgarian citizen, and about your specific characteristics in relation to the latter.
- Implementing/executing/following the legislative requirements of the Family Code; Ordinance No.2 from October 24, 2014 determining the rules and regulations for the issuance and termination of licenses for mediation in intercountry adoption and for the realization/implementation and termination of accredited organizations’ business; Ordinance No.3 from October 24, 2014 determining the rules and regulations for keeping the registers for intercountry adoption and for the granting of consent by the Minister of Justice; the Convention on Protection of Children and Co-operation in Respect of Intercountry Adoption from May 29, 1995, which has been ratified by the Republic of Bulgaria.
- Using the collected data in view of realizing the procedure for intercountry adoption, including the procedural representation, as well as performing the postadoption monitoring within a two-year period, effective from the finalization of the procedure for adoption through the legal enforcement of a court decree.
- Implementing the legislative requirements of the Accountancy Act and other applicable legislative requirements.
- Performing all actions related to the existence, amendment and termination of legal contractual obligations.
- Establishing a connection via telephone, mail and/or electronic mail for the sending of correspondence related to the performance of obligation stated in contracts with the Association.
(2) Family National Association conforms to the following principles when processing your personal data:
- Lawfulness, good faith and transparence;
- Limitation of processing purposes;
- Correlation with the processing purposes and minimization of collected data;
- Accuracy and topicality of the data;
- Limitation of storage in view of the achievement of goals;
- Integrity and confidentiality of the processing and guarantee of an appropriate level of security for the personal data.
Types of personal data collected, processed and stored by Family National Association
Art.2. (1) Family National Association collects, processes and stores the following types of personal data about its clients:
- Related to physical identity: names, personal number, passport data, address, place of birth, telephone number, etc.;
- Related to mental and health identity – documents about current mental and physical health condition;
- Related to economic identity – and more specifically: data for property status;
- Related to cultural identity – interests, hobbies and other leisure activities;
- Related to family identity – marital status (presence of marriage, divorce, number of family members, including children, etc.);
- Related to education – type of education, additional qualifications, etc.;
- Related to employment – professional biography, employment history, etc.;
- Related to the civil and criminal status of the persons – criminal record certificate, information about parental rights, etc.;
- Telephone numbers and e-mail for correspondence.
(2) Family National Association does not perform automated decisions with data.
Term for the storage of your personal data
Art.3. Your collected personal data is stored for a period of 5 years after the finalization of the court case and the obtaining of the 4 post-adoption reports in accordance with the principle of good judicial practice.
Your rights related to collecting, processing and storing your personal data
Withdrawal of consent for the processing of your personal data
Art.4. In case you do not want all or part of your personal data to continue being processed by Family National Association for one specific or for all processing purposes you can withdraw your consent for the processing at any time by filling out an online form or by a request in free form, as long as if at the specific moment this is not in contradiction with the active legislation regulating the procedures for the adoption.
Right of access
Art.5. (1) You have the right to request and receive a confirmation from Family National Association stating whether personal data related to you is being processed.
(2) You have the right to get access to data, related to it, as well as to information related to the collecting, processing and storing of your personal data.
(3) Upon request Family National Association will provide a copy of the personal data connected to you which is being processed, in electronic or other suitable form.
Right of amendment or addition
Art.6. You have the right to amend the inaccurate or incomplete personal data related to you by filing a request to Family National Association.
Right or deletion (“being forgotten”)
Art.7. (1) You have the right to request from Family National Association deletion of the personal data related to you, and Family National Association must, with no unnecessary delay, erase the data when one of the following grounds is present:
- The personal data is no longer necessary for the purposes it has been collected for or processed in any other way;
- You withdraw your consent the processing of the data is based on and there are no other legal grounds for the processing;
- You object to the processing of the personal data related to you, including for the means of direct marketing, and there are no superior legal grounds for the processing;
- The personal data has been processed illegitimately
- The personal data must be deleted for the means of complying with a legal obligation according to EU legislation or a member state legislation enforced to Family National Association.
- The personal data has been collected in relation to the provision of services to the information society.
(2) Family National Association is not obligated to delete the personal data if it stores it and processes it:
- To exercise the right of freedom of speech and the right of information;
- To keep a legal obligation which requires processing, stated in EU legislation or member state legislation which is enforced to the Administrator or for the performance of a task with public interest or while exercising official powers they have been given;
- For reasons of public interest in the area of public health;
- For the purpose of archiving in the interest of the public, for scientific or historic research or for statistical purposes;
- For the establishment, exercise and protection of legal claims.
(3) To exercise your right of “forgetfulness” you must file a request, sent to Family National Association, in writing, as well as certify your identity and identify with the person to whom the data is related by personally presenting your identification card.
(4) Family National Association does not erase the data it has the legal obligation to store, including for defense against legal claims or to prove its rights.
Right of limitation
Art.8. You have the right to demand for Family National Association to limit the processing of personal data related to you, when:
- You contest the accuracy of the personal data within a time period which would allow Family National Association to verify the accuracy of the personal data;
- The processing is unlawful but you do not want your personal data to be deleted but only for their usage to be limited;
- Family National Association no longer needs the personal data for the goals of processing but you require it for the establishment, exercise or protection of your legal claims;
- You have objected to the processing while awaiting an inquiry into whether the legal grounds of Family National Association take priority over your interests.
Right to receive information
Art.9. You can request from Family National Association to inform you about all recipients to whom the personal data, whose correction, deletion or limitation of processing has been requested, has been disclosed. Family National Association may decline providing this information if this is impossible or requires a disproportionate amount of effort.
Right of objection
Art.10. You can object at any time to the processing by Family National Association of personal data related to you, including its processing for the purpose of profiling or direct marketing.
Your rights in case the security of your personal data is breached
Art.11. (1) Should Family National Association establishes a breach in the security of your Personal Data which may lead to a high risk for your rights and freedoms, we notify you with no unnecessary delay of the breach, as well as of measures which have been undertaken or are going to be undertaken.
(2) Family National Association is not responsible for notifying you if:
- It has undertaken suitable technical and organizational measures of protection in relation to the data affected by the breach of security;
- It has subsequently undertaken measures which guarantee that the breach will not lead to a high risk for your rights;
- Notifying you would require a disproportionate amount of effort.
Persons provided with your personal data
Art.12. The administrator submits data to state authorities such as the Ministry of Justice – Central Authority in the sense of Art.6. of the Hague Convention, courts, investigating authorities, prosecution, as well as other revising authorities – upon request for the data in due order in relation to the exercise of their legal rights.
Other provisions
Art.13. In case your rights are violated in accordance with the abovementioned or applicable legislation for the protection of personal data, you have the right to file a complaint at the Commission for Personal Data Protection, as follows:
- Name: Commission for Personal Data Protection
- Head office and address of management: 1592 Sofia, No.2, Prof. Tsvetan Lazarov Blvd.
- Address for correspondence: 1592 Sofia, No.2, Prof. Tsvetan Lazarov Blvd.
- Telephone: +35929153518
- E-mail: kzldgovernment [ad] bg; kzldcpdp [ad] bg
- Website: www.cpdp.bg
Art.14. You may exercise all your rights in relation to the protection of your personal data through the forms attached to the current information. Certainly, these forms are not obligatory and you can extend your request in any form, which contains a statement for this and identifies you as the owner of the data.
Art.15. If the consent is related to a transfer, the Administrator describes the possible risks of data being transferred to third-party states in the absence of means for adequate protection and suitable resources for protection.