PROJECT

POLICY

on the processing of personal data

Website: https://verkhnedvinsk.vitebsk-region.gov.by/

 

Approval date: «» __________ 20.
Effective date: «» __________ 20.
Version: 1.0

 

 

1. General Provisions

1.1. This Policy is developed in compliance with the Law of the Republic of Belarus of May 7, 2021 No. 99-Z "On the Protection of Personal Data" and other legislative acts of the Republic of Belarus in the field of personal data. The Policy defines the procedure for processing and protecting the personal data of users of the website https://verkhnedvinsk.vitebsk-region.gov.by/ (hereinafter referred to as the Website).

 

1.2. The operator of personal data is [full name of the state body/organization], Taxpayer Identification Number (TIN) [●], location: [postal address] (hereinafter referred to as the Operator).

 

1.3. Contact details of the Operator regarding personal data processing: phone [●], email [●], postal address for inquiries [●]. Person responsible for organizing personal data processing: [position, full name — if necessary].

 

1.4. This Policy applies to information that the Operator receives through the Website, including information provided by users when submitting electronic inquiries, requests, messages, applications, and using other services provided by the Website.

 

1.5. Before providing personal data, the User is obliged to familiarize themselves with the Policy. Continued use of the Website by itself does not imply consent to the processing of personal data, unless otherwise provided by legislation or the Website interface. Consent is obtained through a separate method that allows confirmation of its receipt.

 

1.6. This Policy does not apply to third-party websites, links to which may be placed on the Website. The processing of data on such resources is governed by their own documents.

 

2. Key Terms

2.1. The terms «personal data», «processing of personal data», «operator», «data subject», «provision», «distribution», «anonymization», «blocking», «deletion» and other terms are used in the meanings established by the legislation of the Republic of Belarus.

 

2.2. User — a visitor to the Website, including a person submitting an inquiry or other message through the Website.

 

3. Principles of Personal Data Processing

3.1. The operator processes personal data lawfully, fairly and transparently, based on specific, predetermined and lawful purposes.

 

3.2. The content and volume of data correspond to the stated purposes and are not excessive. The operator takes measures to ensure the accuracy of data, guarantees their confidentiality and stores them no longer than necessary to achieve the processing purposes or to comply with legislative requirements.

 

3.3. The Operator does not use personal data for purposes incompatible with the initial purposes of their collection, without a new legal basis or consent, if such consent is required.

 

4. Categories of subjects and composition of processed data

4.1. The Operator may process data of the following categories of subjects: users of the Website; persons sending electronic appeals, requests, and messages; representatives of organizations; other persons whose data is contained in the appeal or attached documents on a lawful basis.

 

4.2. Depending on the service used, the following may be processed: surname, first name, patronymic (if applicable); contact phone number; email address; postal address; information specified in the text of the appeal; information about position and organization; data contained in attachments; technical information about visits to the Website and cookies — in the manner established by a separate Policy on the processing of cookie files.

 

4.3. The User must not send through the Website special personal data, document data, bank details, passwords, and other excessive information, unless this is explicitly required for consideration of the request and is provided for by the corresponding service.

 

5. Purposes and legal grounds for processing

Purpose	Possible Data	Legal Basis
Ensuring the operation and security of the Website	IP address, information about the browser, device, time, and actions on the Website, technical logs	legislation; ensuring functionality and information security
Review of electronic appeals, requests, and messages	Full name, contact details, information from the appeal and attachments	legislation on appeals by citizens and legal entities; consent — if required for a specific processing method
Direction of response to the applicant	email address, phone number, postal address	performance of the Operator's duties and consideration of the appeal
Maintenance of user settings, including interface language	technical identifiers and settings	consent or necessity for the functioning of the relevant feature; see Cookie Policy
Preparation of aggregated visit statistics and improvement of the Website	anonymized or aggregated technical information	consent for targeted cookies or other legal grounds
Performance of duties established by legislation, document retention and protection of the Operator's rights	data contained in documents and logs	legislation of the Republic of Belarus

5.1. If processing is based on consent, the Operator provides the subject with information about the name and location of the Operator, the purposes, the list of data, the validity period of consent, authorized persons, actions with data, methods of processing, rights of the subject, and the consequences of refusal.

 

5.2. The Operator has the right to process data without consent only in cases provided for by Law No. 99-Z and other legislative acts of the Republic of Belarus.

 

6. Methods of processing and storage period

6.1. Processing may be carried out with the use of automated means and without their use, including collection, recording, systematization, storage, clarification, use, provision to authorized persons, anonymization, blocking, and deletion.

 

6.2. Personal data is stored for the period necessary to achieve the corresponding purpose, consider the request, and comply with the requirements of legislation on appeals, archival affairs, accounting, and other mandatory requirements. After the expiration of the period, the data is deleted, destroyed, or anonymized, unless otherwise provided by legislation.

 

6.3. Specific storage periods are established by the file nomenclature, the Operator's local acts, and the requirements of legislation. The Operator does not establish a storage period longer than necessary for the stated purposes.

 

7. Transfer to third parties and cross-border transfer

7.1. The Operator may entrust the processing of personal data to authorized persons on the basis of a contract or other grounds provided by legislation, provided that they comply with confidentiality and security requirements.

 

7.2. Providing data to government bodies, organizations, and other persons is permitted only in the presence of a legal basis provided by legislation or the consent of the subject, when it is necessary.

 

7.3. Before publishing the Policy, the Operator must confirm: the list of hosting providers, website developers/administrators, email services, statistics services, attack protection systems, contact forms, and other third parties that have access to the data. If such parties are located outside the Republic of Belarus or use infrastructure outside the Republic of Belarus, cross-border data transfer and its legal basis must be described separately.

 

7.4. The current project does not assert the presence of cross-border data transfer, advertising services, Google Analytics, Yandex.Metrica, social widgets, or other external services, since access to the Website was restricted by an intermediate redirect page during the check.

 

8. Protection Measures

8.1. The Operator takes legal, organizational, and technical measures to protect data from unauthorized or accidental access, alteration, blocking, copying, distribution, provision, deletion, and other unlawful actions.

 

8.2. Protection measures include access control, appointment of responsible persons, logging of data processing actions, use of information protection tools, redundancy, incident response, and training of employees authorized to process data, within the scope defined by legislation and local regulations.

 

9. Rights of personal data subjects

9.1. A personal data subject has the rights provided by the legislation of the Republic of Belarus, including the right to obtain information about the processing of their data, request corrections in case of inaccuracies, withdraw consent in the prescribed manner, demand cessation of processing or deletion of data when grounds exist, as well as to appeal the actions or inaction of the Operator.

 

9.2. To exercise their rights, the subject submits a written application or electronic request to the Operator using the contact details specified in Section 1. The application must allow identification of the applicant and contain the essence of the request. The Operator considers the request and provides a response within the timeframes and in the manner established by the legislation of the Republic of Belarus.

 

9.3. Withdrawal of consent does not affect the lawfulness of processing carried out prior to its withdrawal and does not terminate processing if there is another legal basis for it.

 

10. Communications via the Website

10.1. If the communication form requires mandatory consent, a separate, clear notice shall be placed next to the form, specifying the purposes, data composition, validity period of consent, processing methods, subject rights, and consequences of refusal.

 

10.2. The consent field must not be pre-checked. Submission of the communication shall be impossible unless only those fields that are genuinely necessary for consideration of the communication or sending a response are filled in.

 

11. Policy Amendments

11.1. The Operator reserves the right to amend the Policy in the event of changes to legislation, the Website’s functions, or the data processing procedures.

 

11.2. The new version shall enter into force from the date of its publication on the Website, unless a different effective date is specified in the version itself. The date of the last update shall be indicated at the bottom of the document.

 

12. Details and contact information for inquiries

Operator: [full name]
Address: [address]
Taxpayer Identification Number (TIN): [number]
Phone: [number]
E-mail: [address]
Policy page: https://verkhnedvinsk.vitebsk-region.gov.by/[path-to-policy]
Last updated: «_» __________ 20 year