EGAP Privacy Notice

1. Introduction

The Ethiopia Germany Apprenticeship Pathway (EGAP) Project respects your privacy and is committed to protecting your personal data.

This Privacy Notice explains how EGAP collects, uses, stores, shares, transfers and protects personal data when you:

• visit the EGAP website;
• complete and submit an apprenticeship application form;
• upload supporting application documents;
• participate in assessments, interviews, selection processes, introductory courses or apprenticeship placement activities; or
• otherwise communicate or interact with the EGAP programme.

Applicants are not required to create an account or log in to the EGAP system. Applications are submitted directly through the online application form. After a successful submission, EGAP sends a confirmation notification to the email address provided by the applicant.

EGAP processes personal data in accordance with applicable data-protection legislation.

EGAP applies principles of lawfulness, fairness, transparency, purpose limitation, data minimisation, accuracy, storage limitation, security, confidentiality and accountability when processing personal data.

2. Age Requirement

EGAP applications are open only to persons who are 18 years of age or older. You must be at least 18 years old at the time of application to submit an application through EGAP.

Your date of birth may be used to:

• verify that you meet the minimum age requirement;
• assess eligibility for the apprenticeship programme; and
• support programme administration where age information is relevant.

EGAP does not knowingly accept applications from individuals below 18 years of age. If EGAP determines that an application has been submitted by a person below 18 years of age, the application may be rejected and the associated personal data may be securely deleted unless there is a lawful reason to retain particular information.

Because all EGAP applicants must be adults, parental or guardian consent is not required to submit an EGAP application.

3. Who Is Responsible for Your Personal Data?

The organisation responsible for determining why and how personal data submitted through EGAP is processed is the Data Controller.

Data Controller

Organisation:
FDRE Technical and Vocational Training Institute

Address:
Addis Ababa, Lamberet

Email:
egap@ftveti.edu.et

Telephone:
+251-116-464455

EGAP may involve Ethiopian and German partner organisations in assessment, selection, training, apprenticeship placement and programme administration.

Where two or more organisations jointly determine the purposes and means of processing personal data, they may act as joint data controllers.

Organisations that process information only on behalf of the EGAP Data Controller may act as Data Processors and will be subject to appropriate data-protection, confidentiality and security requirements.

4. Personal Data We Collect

EGAP collects only information reasonably necessary to receive, assess, process and administer apprenticeship applications and participation in the programme.

4.1 Personal Details

This may include:

• first name;
• middle name;
• last name;
• date of birth;
• gender;
• National ID or other identification number;
• nationality, where required;
• region;
• city or town;
• telephone number;
• alternative telephone number; and
• email address.

4.2 Parent or Family Information

The EGAP application may request certain information about a parent or family member for programme-administration or contact purposes. This may include:

• first name;
• middle name;
• last name;
• relationship to the applicant;
• gender;
• telephone number;
• email address;
• occupation; and
• other necessary contact information.

This information is not collected for the purpose of obtaining parental or guardian consent, because EGAP applicants must be at least 18 years old.

Where an applicant provides personal information relating to another person, the applicant should, where reasonably possible, inform that individual that their information has been provided to EGAP.

5. Academic and Professional Information

EGAP may collect information necessary to determine whether you meet the academic, technical, professional and other eligibility requirements of an apprenticeship opportunity. This may include:

• educational institution attended;
• level of education;
• field of study;
• qualification obtained;
• graduation date;
• grades or examination results;
• technical and vocational qualifications;
• academic transcripts;
• training certificates;
• language qualifications;
• employment or work-experience information; and
• other information relevant to programme eligibility.

6. Application Documents

Applicants may be requested to upload supporting documents such as:

• National ID or another identification document;
• educational certificates;
• academic transcripts;
• curriculum vitae;
• language certificates;
• photographs;
• recommendation or reference documents; and
• other documents necessary for assessment, selection, placement, visa, immigration, travel or programme administration.

Applicants should provide only the documents and information requested by EGAP and should avoid including unnecessary personal or sensitive information.

7. Application, Assessment and Selection Information

During the application and selection process, EGAP may create and process additional information relating to your application, including:

• apprenticeship sector applied for;
• unique application or reference number;
• date and time of application;
• application status;
• eligibility assessment;
• document-verification results;
• assessment results;
• interview results;
• selection decisions;
• assessment-centre information;
• introductory-course participation;
• language-training information;
• apprenticeship placement;
• employer or training organisation;
• programme participation; and
• communications relating to your application.

8. Information Collected When You Submit the Online Form

Applicants do not create an EGAP account.

When you submit an application form, EGAP may automatically process limited technical information necessary to operate and secure the application system, including:

• IP address;
• device type;
• browser type;
• operating system;
• date and time of submission;
• form-submission logs;
• security logs;
• error and diagnostic information; and
• other technical information necessary to detect misuse, investigate technical problems and protect the EGAP platform.

EGAP does not maintain applicant login histories because applicants do not log in to the system.

9. How We Collect Personal Data

Most personal data is collected directly from you through the EGAP application form. Information may be collected when you:

• complete the online application form;
• upload supporting documents;
• submit your application;
• communicate with the EGAP team;
• participate in an assessment or interview;
• participate in an introductory or language course; or
• participate in subsequent apprenticeship-selection activities.

Where legally permitted and necessary, EGAP may also receive relevant information from authorised organisations including:

• educational or TVT institutions;
• assessment centres;
• Ethiopian government institutions;
• German partner organisations;
• participating apprenticeship employers;
• training providers;
• language-training institutions; or
• other authorised organisations involved in validating or administering your application.

10. Email Notifications and Communication

Your email address is an important part of the EGAP application process. When you successfully submit an application, EGAP will use the email address provided in the application form to send you a submission confirmation notification.

The confirmation email may include information such as:

• confirmation that your application was successfully received;
• your application or reference number, where applicable;
• the apprenticeship opportunity for which you applied;
• the date of submission; and
• instructions concerning possible next steps.

EGAP may also use your email address and telephone number to communicate with you regarding:

• missing or incomplete information;
• document verification;
• eligibility;
• assessment arrangements;
• interviews;
• selection results;
• introductory or language training;
• apprenticeship placement;
• administrative procedures; and
• other matters directly related to your application or participation in EGAP.

Application-related communications are considered part of administering your application and are not treated as commercial marketing communications.

EGAP will not use your contact information for unrelated marketing purposes without an appropriate lawful basis and, where required, your consent.

11. Principles Governing Processing

EGAP will process personal data according to applicable Ethiopian and European data-protection principles. Personal data will be:

• processed lawfully, fairly and transparently;
• collected for specified, explicit and legitimate purposes;
• limited to what is adequate, relevant and necessary;
• kept accurate and corrected where appropriate;
• retained only for as long as necessary;
• protected against unauthorised or unlawful processing;
• protected against accidental loss, alteration, disclosure or destruction; and
• processed using appropriate technical and organisational safeguards.

12. Why We Process Your Personal Data

EGAP processes personal data only where an appropriate lawful basis exists. Depending on the processing activity and applicable legislation, this may include the following:

The particular legal basis may differ depending on the organisation processing the information and the nature of the processing.

13. Consent

EGAP will not use blanket consent as the basis for all processing of your application.

Information that is necessary to:

• receive your application;
• assess eligibility;
• conduct assessments;
• communicate with you;
• select applicants;
• arrange placement; or
• administer the EGAP programme

may be processed on another appropriate lawful basis.

Where EGAP relies specifically on consent for an optional purpose, consent will be:

• freely given;
• informed;
• specific;
• clearly presented; and
• provided through an affirmative action.

You may withdraw such consent at any time. Withdrawal of consent does not affect processing that was lawful before the withdrawal.

14. Mandatory Information

Certain information in the application form is mandatory because EGAP requires it to:

• confirm you are at least 18 years old;
• identify you;
• communicate with you;
• determine your eligibility;
• assess your qualifications;
• process your application; or
• meet applicable legal or programme requirements.

Mandatory fields will be identified in the application form. If required information is not provided, you may be unable to submit the application or EGAP may be unable to process it.

15. Sensitive Personal Data

EGAP seeks to avoid collecting sensitive personal data unless such information is genuinely necessary. Where necessary, this could include information relating to:

• health;
• disability;
• biometric identification; or
• other information considered sensitive under applicable data-protection legislation.

For example, information concerning a disability may be processed where reasonably necessary to provide appropriate accommodation during assessment, training, travel or apprenticeship activities.

Where sensitive information is processed, EGAP will apply appropriate legal, organisational and technical safeguards and restrict access to authorised persons.

16. Who We May Share Personal Data With

EGAP does not sell applicants' personal data.

Where necessary for the application and apprenticeship programme, personal data may be shared with authorised recipients including:

• organisations responsible for implementing EGAP;
• relevant Ethiopian government institutions;
• participating German institutions;
• apprenticeship employers in Germany;
• vocational training organisations;
• educational institutions;
• assessment centres;
• introductory-course providers;
• language-training providers;
• programme implementing partners;
• authorised programme staff;
• visa and immigration authorities;
• embassies and consulates;
• authorised IT and hosting providers;
• email service providers used to send application notifications;
• cybersecurity and technical service providers;
• auditors and professional advisers; and
• regulatory, judicial or law-enforcement authorities where legally required.

Only information reasonably necessary for the relevant purpose will be shared. Data processors acting on behalf of EGAP will be subject to appropriate contractual, security and confidentiality obligations.

17. Storage of Personal Data

EGAP will store and process applicant information in accordance with the data-storage and data-sovereignty requirements of the Ethiopian Personal Data Protection Proclamation No. 1321/2024.

Appropriate technical and organisational measures will be implemented to protect information stored in EGAP databases, uploaded-document storage, backups and related systems.

Where applicable Ethiopian legislation requires personal data collected locally to be stored within Ethiopia, the EGAP hosting and backup architecture will be configured accordingly.

18. How Long We Keep Personal Data

EGAP will retain personal data only for as long as reasonably necessary for the purposes for which it was collected. Retention periods may depend on:

• whether an application is completed or abandoned;
• whether an applicant is successful or unsuccessful;
• the duration of the assessment and selection process;
• the duration of training or apprenticeship participation;
• contractual requirements;
• visa and immigration requirements;
• legal obligations;
• programme reporting requirements;
• audit requirements;
• dispute-resolution requirements; and
• limitation periods applicable to legal claims.

EGAP will maintain a Data Retention and Disposal Schedule specifying retention periods for relevant categories of personal data. Once information is no longer required, it will be securely:

• deleted;
• destroyed;
• anonymised; or
• archived where continued retention is legally required.

19. How We Protect Personal Data

EGAP will implement appropriate technical and organisational security measures proportionate to the sensitivity of applicant information and associated risks. Measures may include:

• role-based access control;
• least-privilege access;
• strong administrator authentication;
• encryption in transit;
• encryption at rest where appropriate;
• secure transmission of uploaded documents;
• secure email configurations;
• security logging;
• audit trails;
• monitoring;
• secure backups;
• vulnerability management;
• system patching and updates;
• malware protection;
• network-security controls;
• restricted administrative access;
• periodic access reviews;
• backup and recovery procedures;
• confidentiality requirements for staff; and
• appropriate security obligations for service providers.

Access to applicant information will be limited to authorised persons who require it for legitimate EGAP purposes.

20. Your Data Protection Rights

Subject to applicable Ethiopian law, the GDPR where applicable, and any lawful exemptions, you may have rights including:

Right to Be Informed

You have the right to receive clear information about how EGAP processes your personal data.

Right of Access

You may request confirmation of whether your personal data is being processed and obtain access to your personal data.

Right to Rectification

You may request correction of inaccurate information and completion of incomplete information. Because applicants do not have an EGAP account through which they can edit submitted applications themselves, requests to correct information after submission should be made directly to EGAP.

Right to Erasure

Where applicable legal conditions are satisfied, you may request deletion of your personal data.

Right to Restrict Processing

You may request restriction of processing in circumstances provided by applicable law.

Right to Object

Where permitted by law, you may object to certain processing, including processing based on legitimate interests.

Right to Withdraw Consent

Where processing is based on consent, you may withdraw your consent.

Right to Data Portability

Where applicable, you may request eligible personal information in a structured, commonly used, machine-readable format.

Rights Concerning Automated Decisions

You may have rights relating to decisions based solely on automated processing that significantly affect you.

Right to Complain

You may raise a complaint with EGAP or the competent data-protection supervisory authority.

21. How to Correct or Update an Application

Since applicants do not create accounts and cannot directly edit an application after submission, you should contact EGAP if you discover that information submitted in your application is:

• incorrect;
• incomplete;
• outdated; or
• otherwise needs to be corrected.

When contacting EGAP, you may be asked to provide your:

• name;
• application/reference number;
• email address used for the application; and
• information necessary to verify your identity.

This helps EGAP prevent unauthorised persons from changing another applicant's information.

Application support:
[Insert EGAP application-support email]

22. How to Exercise Your Data Protection Rights

Privacy-related requests may be submitted to:

EGAP Privacy Contact
Email: egap@ftveti.edu.et

Because EGAP does not provide applicant accounts, requests for access, correction, deletion or other rights will normally be handled through verified direct communication.

EGAP may require reasonable information to confirm your identity before responding to a request. Requests will be handled without undue delay and within the timeframe required by applicable law.

23. Automated Decision-Making

EGAP does not intend to make final apprenticeship acceptance or rejection decisions solely through automated processing where such decisions would have legal or similarly significant effects on applicants.

The EGAP system may automatically perform administrative functions such as:

• checking that mandatory fields are completed;
• calculating whether an applicant meets the minimum age requirement;
• validating data formats;
• checking uploaded-document requirements;
• generating an application/reference number;
• recording the submission;
• detecting possible duplicate submissions; and
• sending a confirmation email after successful submission.

These functions do not constitute a final apprenticeship selection decision. Final eligibility, assessment and selection decisions should involve appropriate human review.

24. Cookies and Website Technologies

The EGAP website may use essential cookies or similar technologies necessary to:

• maintain the application session while the form is being completed;
• protect the application form against misuse;
• provide security functionality;
• prevent fraudulent or automated submissions; and
• ensure reliable operation of the website.

Since applicants do not create accounts, cookies are not used to maintain persistent applicant login sessions.

Non-essential analytics or similar technologies will only be used where permitted by applicable law and, where required, after obtaining consent. Additional information may be provided through a separate EGAP Cookie Notice.

25. Personal Data Breaches

EGAP maintains procedures for identifying, investigating, containing, documenting and responding to personal data breaches.

Where required by Ethiopian data-protection law or the GDPR, EGAP will notify the appropriate supervisory authority. Where applicable law requires affected individuals to be notified, EGAP will communicate appropriate information concerning:

• the nature of the breach;
• possible consequences;
• measures taken or proposed;
• recommended actions, where relevant; and
• contact information for further assistance.

26. Third-Party Websites

The EGAP website may contain links to external websites operated by:

• partner organisations;
• apprenticeship employers;
• training institutions;
• Ethiopian government institutions;
• German organisations; or
• other third parties.

These organisations may have their own privacy practices. EGAP is not responsible for the independent processing practices of third-party websites, and applicants are encouraged to review the relevant privacy notice before submitting personal information to an external website.

27. Complaints

If you have concerns about how EGAP processes your personal data, you are encouraged to contact:

EGAP Privacy Contact
Email: egap@ftveti.edu.et

28. Changes to This Privacy Notice

EGAP may update this Privacy Notice where necessary due to:

• changes to the application process;
• changes to the apprenticeship programme;
• introduction of new system functionality;
• changes to programme partners;
• changes to data-processing activities;
• changes to hosting or infrastructure;
• changes to applicable legislation; or
• new regulatory guidance.

The latest version will be published on the EGAP website together with the date it was last updated.

29. Contact Information

For questions about this Privacy Notice or EGAP's processing of personal data, contact:

Ethiopia Germany Apprenticeship Pathway (EGAP)

Data Controller:
FDRE Technical and Vocational Training Institute

Address:
Addis Ababa, Lamberet

Privacy Email:
egap@ftveti.edu.et

Telephone:
+251-116-464455