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BHN ACADEMY GERMANY
Information for scholarship applicants, enrolled scholars and programme participants worldwide
This Student Data Privacy Notice explains how Bechem Humanitarian Network (BHN) e.V. collects, uses, shares, protects and retains personal data in connection with BHN Academy Germany. It covers scholarship applications, enrolment, identity verification, learning activities, certification, capstone projects and programme communications. This notice supplements the general BHN e.V. Privacy Policy at https://bhnverein.org/ and applies alongside the Scholarship Enrollment Agreement accepted by enrolled scholars.
BHN Academy Germany is the educational branch of Bechem Humanitarian Network (BHN) e.V., a registered nonprofit association under German law. It is not a separate legal entity or an independent data controller. BHN e.V. determines the purposes and means of processing Academy applicant and student data and is the controller for the processing described in this notice.
Data controller: Bechem Humanitarian Network (BHN) e.V.
Registered address: Gärtnerweg 8, 93092 Barbing, Germany
Privacy contact: info@bhnverein.org
Telephone: +49 152 15003159
Websites: https://bhnverein.org/ and https://academy.bhnverein.org/
BHN processes Academy information in accordance with the EU General Data Protection Regulation (GDPR), the German Federal Data Protection Act (BDSG) and other applicable data-protection laws. This protection applies to personal data processed by BHN in Germany regardless of whether a student lives within or outside the European Economic Area (EEA). Where relevant, applicable data-protection requirements in a student's country of residence are also observed.
For questions about the processing of Academy information or to exercise data-protection rights, students and applicants may contact BHN using the privacy contact details above. BHN e.V. handles these enquiries as the organisation responsible for BHN Academy Germany's personal-data processing.
This notice applies to applicants, prospective scholars, waitlisted applicants, selected or enrolled scholars, former scholars and participants in Academy-related mentoring, capstones, surveys or educational activities. It covers application and screening, eligibility assessment, identity verification, contractual enrolment, access to digital-learning services, performance monitoring, scholarship administration, completion, impact reporting and post-programme records.
General website visits, optional cookies, website analytics and unrelated BHN activities are also described in the organisation-wide BHN Privacy Policy and the relevant cookie information.
Depending on the questions presented in a particular application form, BHN collects the following information directly from applicants:
Applicants should provide accurate answers to the questions asked. Medical details, identity documents, political or religious information and other sensitive personal information should not be added to free-text fields unless they are specifically requested for a stated programme purpose.
When a scholarship is offered, BHN may collect additional information through the BHN Digital Impact Fellowship or other Academy enrolment processes, including:
BHN uses the submitted government-issued ID and student photograph to confirm identity, prevent impersonation and fraud, and maintain accurate enrolment records. Original document images are available only to personnel authorised to carry out verification or related investigations. Submission of the specified identity document and a recent passport-style photograph is a mandatory part of scholarship enrolment.
During participation, BHN and the educational platforms used for the scholar's track may generate or exchange data necessary to deliver and administer the scholarship. This can include platform account identifiers, enrolled courses, access status, login or activity dates, recorded learning hours, assessments or course milestones, completed courses, certificates and credential details, capstone participation, programme communications and disciplinary or integrity-review records where applicable.
BHN uses learning-progress information to administer and safeguard limited sponsored places, verify the eight-hour weekly engagement requirement and other scholarship conditions, decide on continuation or renewal, apply the agreed withdrawal rules, protect Academy and partner accounts, demonstrate delivery and maintain necessary audit evidence. Relevant processing may continue after a scholarship ends where a lawful records-retention purpose applies.
BHN processes applicant and student data for the purposes set out in this section. The applicable legal bases are identified for each activity. Acceptance of the Scholarship Enrollment Agreement is recorded at enrolment and covers the stated scholarship conditions, capstone requirements and publication provisions. BHN does not normally request a further signature for subsequent uses already covered by the accepted terms and a valid legal basis.
6.1 Applications, screening and selection – Article 6(1)(b) GDPR. BHN uses information supplied in applications to assess eligibility, review scholarship criteria, maintain waiting lists, communicate with applicants and issue selection decisions. BHN may also rely on Article 6(1)(f) GDPR for its legitimate interest in administering a fair scholarship process, identifying duplicate applications, protecting available scholarship places and keeping necessary selection records.
6.2 Scholarship administration and delivery – Article 6(1)(b) GDPR. BHN processes required application and enrolment information to establish the scholarship relationship, confirm the selected study track, provide learning-platform access, communicate programme requirements, manage the enrolled scholar's learning account and issue or verify credentials. Information collected for these purposes is used throughout the scholarship to provide and administer the agreed educational services.
6.3 Identity verification and prevention of misuse – Articles 6(1)(b) and 6(1)(f) GDPR. BHN verifies selected scholars using the submitted identity document, student photograph and enrolment details. These checks help prevent impersonation, duplicate scholarship placements, fraudulent access and incorrect certificate details. BHN retains a limited verification record and may review relevant evidence in a documented fraud or identity dispute. Uploaded document copies are handled according to applicable German identity-document requirements.
6.4 Learning monitoring, scholarship conditions, withdrawal and integrity – Articles 6(1)(b) and, where applicable, 6(1)(f) GDPR. BHN processes recorded learning hours, login activity, progress, completed courses, compliance information and related correspondence to monitor participation and apply the terms of the Scholarship Enrollment Agreement. This includes the minimum eight hours of study per week and the agreed withdrawal consequence after three consecutive weeks below the requirement. BHN retains appropriate records of scholarship decisions, integrity concerns and related enquiries or disputes.
6.5 Institutional accountability and impact reporting – Article 6(1)(f) GDPR. BHN uses programme information to evaluate scholarships, prepare statistics, demonstrate educational achievements, report outcomes to funding and educational partners and communicate the results of its nonprofit programmes. This processing supports BHN's legitimate interests in programme accountability and public-benefit reporting. Where identifying a scholar is not necessary, information is presented in an anonymised or aggregated form. Publication of identifiable achievements is described in sections 6.7 and 15.
6.6 Mandatory capstone completion and partner sharing. Completion of a capstone and the partner-sharing provisions of the Scholarship Enrollment Agreement are mandatory conditions of the scholarship. BHN may share the scholar's name, selected study track, capstone title, project materials, certificates, achievements and relevant professional information with educational and professional partners for programme delivery, assessment, achievement reporting, professional networking and showcasing programme outcomes. BHN records the scholar's initial acceptance at enrolment. Educational delivery is generally processed under Article 6(1)(b) GDPR; related reporting and programme communications rely on an applicable legal basis, including Article 6(1)(f) where appropriate. Relevant intellectual-property and international-transfer requirements apply.
6.7 Mandatory enrolment publicity release and subsequent publications. Scholars accept the publicity and achievement-sharing provisions set out in the Scholarship Enrollment Agreement when they enrol. Within the scope of those provisions, BHN may publish a scholar's name, certificates, professional photographs, achievements and authorised project information on BHN websites, official social-media channels, in programme reports and institutional communications, and through relevant partner communications. The acceptance is recorded once at enrolment; BHN does not routinely request a second authorisation for later uses lawfully covered by it. Identifiable publications are subject to the applicable GDPR legal basis and German rights-to-image requirements. Government-ID copies and private application details are not published under this release.
6.8 Legal obligations, proof of agreement and defence of BHN interests – Articles 6(1)(c) and 6(1)(f) GDPR. BHN retains relevant records of the accepted scholarship terms, enrolment and identity verification, award and withdrawal decisions, serious integrity incidents and publications where necessary for statutory compliance, audits, programme accountability and the establishment, exercise or defence of legal claims. These records are kept for the periods described in section 13, subject to applicable law.
BHN's recorded enrolment acceptance covers the scholarship conditions and defined permissions contained in the accepted agreement. Further routine administration, partner communication and publications within that valid scope do not require scholars to complete the same acceptance again. The permitted uses remain those described to students at enrolment and in this privacy notice.
An applicant's answers about eligibility, personal circumstances, gender, employment, vulnerability or previous experience may contain personal information requiring additional care. BHN uses this information for scholarship eligibility, selection, programme administration and evaluation. Some voluntary statements or supporting information may also reveal health, ethnic origin, religious beliefs, political views or other specially protected information.
BHN does not routinely require special-category personal data for Academy enrolment. Where such information is necessary for a specific programme activity, BHN processes it only under an applicable Article 6 GDPR legal basis and an Article 9 GDPR condition. Access is restricted, and only the information needed for that purpose is retained. Programme results and impact statistics are anonymised or aggregated where possible.
Eligibility and scholarship decisions are not based on irrelevant sensitive attributes. Information gathered to assess underserved or priority populations is not routinely disclosed to learning-platform providers merely to provision a course account.
BHN requires a government-issued ID and a recent portrait photograph from each selected scholar to verify identity, prevent fraudulent enrolment and ensure certificate details are accurate. Government-ID copies are used for restricted verification, related integrity investigations and legally justified audit functions, not for public release. The mandatory enrolment publicity provisions govern the stated use of students' professional photographs, certificates and achievements, subject to the applicable rules governing publication.
BHN's standard enrolment verification does not involve automated biometric identification or the creation of facial-recognition templates from submitted photographs or identity documents.
BHN handles copies of national identity cards and passports in accordance with applicable German identity-document laws, including the rules governing copying and disclosure. The uploaded document is used to confirm the personal details and identity of the scholar and is accessible only to authorised personnel. Full copies are deleted under the retention schedule in section 13, except where a documented verification dispute, investigation or legal obligation requires temporary further retention.
Most application and identification details are supplied by the applicant. BHN may also receive relevant enrolment, activity, course-completion or certification information from the education provider used for the scholar's programme. Where justified, BHN may receive referral or eligibility information from an institutional partner, or factual information from a named reference after the reference has been contacted.
If BHN obtains personal data about a scholar from a provider, reference or other third party, it informs the affected person where required by the GDPR. Information about references and institutional contacts is used for the relevant application or scholarship purpose and is not used for unrelated communications.
Personal data are accessible only to the BHN team members and service providers who reasonably require them for authorised Academy work, with access limited by role. Depending on the programme and the service actually used, recipients or categories of recipients can include:
BHN uses authorised service providers for hosting, applications, documents, communications, learning administration and programme reporting. Providers processing information on BHN's behalf operate under applicable data-processing arrangements. Educational partners that independently determine their processing activities are responsible for their own privacy information. BHN shares information needed to administer scholarships, verify achievements and undertake the partner communications covered by the scholarship programme. Government-issued identification documents are not provided to educational partners for unrelated marketing.
In particular, ID images and verification photographs may be stored by BHN's approved form and cloud-storage processor while they are being reviewed; they are not shared with educational partners merely to create a course account. Forms involving file uploads may require an applicant to use a Google account, which is also subject to Google's applicable account information.
BHN operates from Germany and serves scholars worldwide. It may provide necessary personal data to approved educational partners, authorised programme administrators or social-media operators outside the European Economic Area. Information intentionally published on a public website or social-media channel may be viewed, copied and re-shared internationally, and BHN may not be able to remove independent third-party copies after lawful publication.
Where personal data are transferred outside the EEA, BHN applies an appropriate transfer mechanism as required by the GDPR. Depending on the destination and recipient, safeguards may include a European Commission adequacy decision, the EU-U.S. Data Privacy Framework for eligible certified organisations, European Commission Standard Contractual Clauses or another mechanism permitted by law. These arrangements support the lawful use of international educational and technology services involved in Academy programmes.
BHN applies the safeguards described above to relevant transfers. Information on the applicable safeguards and the means of obtaining a copy is available from info@bhnverein.org in accordance with Article 13 GDPR. Publication on globally accessible websites and social-media services may also involve subsequent sharing by third parties outside BHN's control.
The BHN Scholarship Enrollment Agreement requires scholars to engage in at least eight hours of study each week. Under the stated minimum-engagement rule, failure to reach that requirement for three consecutive weeks results in automatic withdrawal of the scholarship place and its reassignment, without an advance-warning requirement. Other published agreement provisions govern suspension, fraud, breaches of academic integrity, termination and future eligibility. BHN uses the corresponding participation and administrative records to enforce these binding conditions.
BHN uses the learning-platform records and relevant administrative information to determine whether scholars have met the minimum engagement requirements in their agreement. The stated scholarship withdrawal, suspension and other participation conditions are applied in accordance with the signed terms. Where a decision is made solely by automated processing and produces legal or similarly significant effects, BHN applies the safeguards and rights required under Article 22 GDPR.
BHN may retain a documented record of the reason, applicable condition and effective date of withdrawal, together with the electronic acceptance and underlying evidence, for the retention periods stated below. BHN does not use the government-ID portrait for automated facial profiling as part of standard scholarship administration.
BHN retains applicant and student information for the periods below. Retention depends on the type of record and its purpose, including application review, identity verification, scholarship administration, learning progress, certification, programme reporting and fulfilment of legal obligations. When a retention period ends, BHN deletes or anonymises the information unless it must be kept for an ongoing dispute, a legal obligation or another permitted reason. Access to retained records is limited to authorised personnel and service providers.
13.1 Incomplete applications – up to 90 days after the last saved activity. Where BHN holds a partly completed application, the information is deleted after 90 days of inactivity unless it has been submitted or is required to complete an active support enquiry. Applications that were never saved or submitted are not retained by BHN.
13.2 Rejected, ineligible or withdrawn applications – 12 months from the final decision or withdrawal. BHN keeps the submitted application, relevant screening information, decision and related correspondence for up to 12 months to respond to enquiries, document selection decisions and handle disputes. Unnecessary attachments and duplicates may be deleted sooner. Information required for a specific investigation, claim or audit is kept only for the additional necessary period.
13.3 Waiting-list applications – while the waiting list is active, up to 12 months from the relevant selection decision. BHN retains eligible reserve applications so that available scholarship places can be offered to candidates on the waiting list. Once that period ends, the application is deleted unless it is needed for a further scholarship process on a lawful basis.
13.4 Uploaded national-ID and passport copies – during identity verification and, where needed for immediate quality checks or a verification dispute, up to 90 days after the final verification result. BHN normally deletes full government-ID or passport images within this period and retains a limited verification record separately. When an identity dispute, suspected forgery or active legal investigation requires the original image, access is restricted and the document is kept only while the matter remains open. The need for any extended retention is reviewed at least every 90 days, and the image is deleted when no longer required.
13.5 Enrolment portrait kept for identity checks – during the scholarship and up to 12 months after completion, cancellation or withdrawal. BHN keeps the identification portrait to support account security, enrolment verification and investigation of suspected impersonation. Photographs lawfully published under the scholarship publicity provisions follow the separate period in paragraph 13.10.
13.6 Verification results, scholarship acceptance and necessary application/enrolment files – throughout the scholarship, then normally until 31 December of the third calendar year after the year in which the scholarship relationship ended. BHN retains the verification outcome, accepted programme terms and date of acceptance, scholarship allocation, important communications, compliance findings, relevant decisions and necessary evidence of enrolment or withdrawal. These records support scholarship accountability, audits and the handling of related legal claims.
13.7 Learning activity and programme-performance records – throughout the scholarship and ordinarily up to 24 months after it ends. BHN retains information on participation, course progress, recorded study hours, completion and related learning activity to address academic enquiries, measure programme outcomes and support scholarship administration. Where particular records are required to establish or defend a legal claim, the period in paragraph 13.6 may apply.
13.8 Issued certificates and essential credential-verification records – throughout enrolment and for up to five years after the certificate is awarded or the scholarship ends, whichever is later. BHN retains necessary credential details such as the scholar's name, certification title, issuing or completion date and study track to verify qualifications, confirm achievements and prepare programme reports. Detailed activity logs follow their own retention period in paragraph 13.7.
13.9 Capstone submissions, project abstracts and approved showcase materials – throughout the scholarship and generally for up to five years after it ends. BHN retains submitted project materials, capstone titles, abstracts and authorised showcase materials to verify completion, document outcomes, make the agreed disclosures to programme partners and report on the scholarship's impact. Where personal identification is no longer necessary, the material may be anonymised; anonymised project examples may be retained longer.
13.10 Published name, achievements, certificates, photos and authorised communications – publication remains accessible for as long as it serves the specified programme-reporting or institutional-communications purpose, ordinarily for up to five years after BHN's most recent publication. BHN reviews continued use at least annually. Materials necessary for lawful institutional archives, funding reports or other documented purposes may be retained longer. Requests concerning identifiable published information are handled under applicable data-protection and image-rights law. BHN cannot ensure that independently saved or reshared third-party copies are removed.
13.11 Evidence of publicity and capstone-sharing authorisation – for as long as the related project or identifiable publication is lawfully used, and ordinarily until 31 December of the third calendar year after the last relevant use. BHN keeps the applicable version of the Scholarship Enrollment Agreement, time-stamped acceptance and relevant publication records to demonstrate the scope of the permissions granted and respond to any later enquiry or legal claim.
13.12 Substantiated integrity and scholarship-exclusion records – for the period needed to administer an applicable scholarship exclusion or other integrity measure, subject to review at least annually. BHN may retain a limited record of the exclusion status, grounds and effective dates to protect the scholarship programme. Supporting evidence is retained for the relevant claims period and deleted or restricted when no longer necessary. Government-ID images remain subject to their separate retention rules.
13.13 Surveys and impact questionnaires – identifiable responses are ordinarily retained for up to 24 months after the relevant survey or evaluation is completed. BHN uses survey responses to measure educational and social outcomes and improve its programmes. Aggregated statistics that no longer identify individuals may be retained for longer. Where a survey uses a different retention period, this is stated at the time the information is collected.
13.14 Contact, account and security logs – routine correspondence is ordinarily retained for up to 24 months after an enquiry is closed unless it is part of an active scholarship or legal record. Routine system-access and security logs are generally deleted within 30 to 90 days. Logs associated with a security incident or investigation may be held for the additional period needed to complete that matter.
13.15 Statutory books, accounting and tax records – qualifying records are retained for six, eight or ten years, according to the relevant German tax, accounting or other statutory requirements. These statutory periods apply to documents within the relevant accounting or tax categories, such as qualifying invoices and financial records, rather than to all application and enrolment information.
13.16 Legal holds, external records and backups – BHN may retain necessary records beyond a standard period for an ongoing legal claim, investigation, binding funder audit or other legal obligation, with restricted access for the duration of that purpose. Deleted records may remain temporarily in secured backups until the normal backup-replacement cycle is completed. Learning providers and social-media platforms acting as independent controllers follow their own retention policies.
BHN implements technical and organisational safeguards appropriate to the sensitivity of the information and the risk to the individuals concerned. Safeguards include proportionate role-based access, authentication, restricted document sharing, secure transmission and storage, review of authorised personnel, staff confidentiality, protection against loss or unauthorised changes, and secure deletion procedures. Security arrangements are reviewed when systems or risks change.
BHN assesses personal-data incidents and, where required, reports a qualifying breach to the competent supervisory authority within the GDPR timeframe and informs affected individuals where the legal notification threshold is met. No digital service can be guaranteed to be completely risk-free.
15.1 Mandatory conditions accepted at enrolment. Scholars must accept the Scholarship Enrollment Agreement, including the capstone and defined partner-sharing and publicity provisions, before the scholarship is activated. Applicants may accept these conditions or decline the award. BHN records the date and version of the accepted terms and uses this record to administer the scholarship and the associated communications and disclosures described in the agreement.
15.2 Publicity release recorded at enrolment. The scholarship publicity provisions cover BHN's use of the scholar's name, certificates, professional photographs, achievements and authorised project information on official websites, social-media channels, programme reports and relevant partner communications. BHN records this acceptance once. It does not routinely seek additional approval for each later publication already within the scope of an effective enrolment release and an applicable legal basis. Government-issued identification documents and confidential application information are excluded from ordinary publicity.
15.3 Continuing uses and partner distribution. BHN may feature authorised student achievements, certificates, photographs and capstone materials in programme announcements, scholarship reports, digital communications, Academy website content and materials shared with approved educational or professional partners. This may include subsequent reports on achievements arising from the same scholarship. The material used remains within the stated purposes and scope of the accepted provisions, and BHN keeps relevant acceptance and publication records for the retention periods in section 13.
15.4 International social-media publication. Information made public on a BHN website or social-media platform may be seen by people anywhere in the world. Social-media operators and other users may store, share or repost published content. BHN manages the material on its own channels and responds to applicable legal requests, but cannot guarantee removal of copies made or redistributed independently by third parties.
15.5 Scope of public dissemination. Public programme communications may identify scholars and their achievements, certificates, professional photographs or authorised project contributions as described in the Scholarship Enrollment Agreement. BHN does not publish passport or national-ID images, confidential contact details or sensitive application responses as part of routine scholarship publicity. The processing and publication of identifiable information remains subject to applicable data-protection and German image-rights law.
Where a BHN Academy programme admits applicants under 18, BHN provides information suitable for their age and uses appropriate safeguards for personal details, identity verification, platform access and publicity. Parental or guardian authorisation is obtained where required by applicable law. Young participants' information is collected and used only to the extent necessary for the stated Academy purposes and is covered by the same rights and retention principles described in this notice.
Mandatory application and enrolment information is required to assess scholarship eligibility, confirm identity, establish the scholarship relationship and grant access to supported courses. Applicants who do not provide the required information or do not accept the mandatory terms cannot complete enrolment. Once the agreement has been accepted, BHN uses the information for the scholarship purposes set out in this notice without seeking a new permission each time a routine administrative activity is performed.
The Scholarship Enrollment Agreement sets out the programme's compulsory participation, capstone and publication provisions. BHN retains the record of accepted terms, applies its participation and scholarship-withdrawal rules, and processes data for the stated purposes. Personal-data requests, legal objections and applicable rights are handled in accordance with section 18 and the relevant data-protection laws.
Subject to the relevant legal conditions and exceptions, students and applicants have the following rights:
BHN reviews requests concerning personal information and responds within the periods prescribed by the GDPR. Some records may be retained while necessary to administer an active scholarship, comply with statutory duties, meet audit requirements or establish, exercise or defend legal claims. Where a request concerns published material, BHN assesses the legal basis for that specific processing and any applicable rights or exceptions. The outcome is communicated to the person making the request.
Requests can be sent to info@bhnverein.org with the subject 'BHN Academy Germany – Data Protection Request'. Please do not attach an ID document unless specifically requested via a secure process.
BHN is a private-law nonprofit based in Bavaria. The competent data-protection supervisory authority for this sector is:
Bayerisches Landesamt für Datenschutzaufsicht (BayLDA)
Promenade 18, 91522 Ansbach, Germany
Website: https://www.lda.bayern.de/
Telephone: +49 (0) 981 180093-0
Individuals may lodge a complaint with the BayLDA, or another competent EU/EEA supervisory authority where the GDPR permits, including one in the Member State of their habitual residence, place of work or place of an alleged infringement. Applicants may contact BHN first, but are not required to do so before approaching a supervisory authority.
The general BHN e.V. Privacy Policy governs other organisational processing and general website functions. The relevant cookie notices apply to the use of cookies and similar technologies on BHN-operated sites. Educational platforms acting as independent controllers provide their own privacy information in respect of activities they determine themselves.
BHN may update this notice to reflect changes in Academy activities, information handling, educational partners, retention practices or applicable law. The latest version is made available through the official Academy and BHN information channels and identifies its effective date. The Scholarship Enrollment Agreement remains the source of the programme terms accepted by enrolled scholars.
Bechem Humanitarian Network (BHN) e.V. – Germany
BHN Academy Germany | Advancing inclusive digital transformation across Africa and the Global South