Freedom of Information Center of Armenia.

On November 30, 2018 Freedom of Information Center of Armenia applied to the Personal Data Protection Agency, asking to study the issue of processing of children's personal data by a e-service www.dasaran.am. FOICA considered it problematic that the website www.dasaran.am actually processes various personal data of all school children in Armenia, but the scope of their development is unknown, and some information about the actions taken by them is suspected of being illegal or disproportionate to the processing of personal data. They cause, for example, the transfer of personal data to others or the use data for commercial purposes.

On the initiative of the Personal Data Protection Agency on the application of the Freedom of Information Center, on December 3, 2018, it initiated administrative proceedings N-021/12/18.

As a result of the proceedings, the Agency decided:

• The development of personal data within the framework of the "Classroom" educational program does not contradict the principle of legality of the processing of personal data defined by Articles 4 and 8 of the RA Law on Personal Data Protection.
• The development of personal data within the framework of the "Classroom" educational program does not contradict the principle of proportionality of personal data processing defined by Article 5 of the RA Law on Personal Data Protection.
• In case of processing personal data within the framework of "Classroom" educational program, the security of processing personal data defined by Article 19 of the RA Law "On Protection of Personal Data 23" is ensured.
• To the "New Generation School" NGO to ensure the proper notification (notification) of the users of dasaran.am website to obtain consent.

The Agency Decision