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Proposed revision: 11th June 2021

Description of the eduroam Service

eduroam (education roaming) is a secure, world-wide roaming access service developed for the international research and education community. eduroam allows any user from an eduroam participating site to get network access at any location that provides eduroam service.

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To view the general Privacy Notice for GÉANT, please visit the GÉANT website.

Why We Process Personal Data

We process various data in order to provide a reliable and secure eduroam service and to ensure and improve the quality of the eduroam supporting service. The eduroam service is designed in a way that we don’t need to know end user identity in order to provide the service. Partners within eduroam community can anonymise potential end user’s private data.  We give advice and guidance to the community that recommends the highest levels of anonymity of data in all deployments.

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We also collect data related to NROs, IdPS and SPs to enable supporting services and improve incident response and user support. Access to the data collected in the eduroam database and other supporting services which is considered private is limited (via authentication mechanism based on eduGAIN) to responsible personnel of GÉANT and NROs.

What Personal Data We Process

As part of the eduroam service, we process the following data:

  • When you roam and visit other countries, or as a user of the eduroam Managed IdP or Managed SP services, the European proxy servers will receive and log the following data: your realm (denoting your institution and federation) and MAC addresses. We can also receive your username if you have not chosen to anonymise this data (eduroam Managed IdP always uses opaque usernames). When you roam to another institution within your home country the European proxy servers don’t receive any data because they are not included in that process.  The service has a legitimate interest in processing this information.
  • When you roam and visit other countries or other institutions within your federation we may also process for monitoring, measuring and reporting services, in addition to the data mentioned above, the data about visited country, visited institution and authentication outcome. The service has a legitimate interest in processing this information.
  • As part of supporting activities we maintain several public web sites (e.g. web site of the Configuration Assistant Tool - CAT service https://cat.eduroam.org)  of) where we collect normal web server logs, i.e. timestamp of access, IP address which requested the page, the page being requested, the HTML result code, etc. The data collected is for the purpose of troubleshooting and debugging potential problems of with eduroam web servers and therefore the service has a legitimate interest in processing this information.
  • The eduroam Operational Team maintains a database where we collect data that may include namee-mailphone number of the NROs, IdPS and SPs contacts to enable supporting services and improve incident response and user support. The data is provided by the NROs based on the eduroam Policy Service Definition. eduroam strongly advises NROs to use the function contacts rather than the personal ones.
  • To ensure proper functioning of the eduroam Configuration Assistant Tool (CAT) and of the eduroam Managed IdP we collect the identifiers and e-mail addresses of the NRO and IdP administrators responsible for the configurations that will be used by the end users. The service has a legitimate interest in processing this information.
  • To ensure proper functioning of the Managed SP service we collect the identifiers and e-mail addresses of the NRO and SP administrators responsible for the configuration of the service that will be used by the end users. The service has a legitimate interest in processing this information.
  • The eduroam Managed IdP system also stores an arbitrary identifier for you (given by the IdP administrator), and maintains pseudonyms of that identifier for the actual eduroam access credentials. It also stores information about successful authentications linked to those pseudonyms. This processing is part of the contractual requirements for eduroam Managed IdP as part of service delivery.
  • Your IdP administrator for eduroam Managed IdP may choose to send you an invitation link via SMS or e-mail.  We will process this data in order to send you the invitation link but the data will not be stored. 

Who Do We Share Data With?

Personal data gathered for website statistics is only shared within GÉANT and the eduroam Operational Team for analysis and reporting.

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All other personal data is held and processed only by the eduroam OT.  

Personal Data Retention

Analytical data for website statistics is currently retained permanently.

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Personal data stored as part of your credentials issued via eduroam Managed IdP are kept as long as you use those credentials for eduroam access, and until they are removed by the IdP administrators. SMS or e-mails processed in order to send you invitation links are not retained.

Security

We support the following processes to ensure the security of your data:

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With these measures we intent to minimize the risk of disclosure of your personal data.

YourRights

You have the following rights regarding your personal data:

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Please feel free to contact us for any further questions, through this email address:  GDPR@GEANT.ORG

Contact Information

Data Controller and Contact

Data Protection Officer

GÉANT Association
Hoekenrode 3
1102 BR
Amsterdam – Zuidoost
Netherlands
Telephone number: +31 20 530 4488
email: gdpr@geant.org

Jurisdiction

Netherlands

Dutch Data Protection Authority
Autoriteit Persoonsgegevens
Postbus 93374 2509 AJ DEN HAAG.
Telephone number: (+31) – (0)70 – 888 85 00.

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