Exceptionally, and until the end of the current academic year 2019-2020, primary and secondary education schools are permitted to provide synchronous distance learning (i.e., real-time teaching by educators using appropriate technological tools).

a) For schools under temporary suspension as a measure to address the COVID-19 pandemic, synchronous distance learning may be conducted for the duration of the suspension. The schedule is determined by the school principal in collaboration with the teaching staff and follows the Ministry of Education and Religious Affairs' existing guidelines.

b) For schools not under suspension due to COVID-19, synchronous distance learning is conducted in accordance with each school’s regular weekly timetable per class, which may be modified by the principal and teaching staff to address specific needs. In such cases, simultaneous synchronous distance learning is provided, enabling simultaneous teaching to students attending the class in person and those unable to attend due to being part of high-risk groups for severe COVID-19 infection, as defined by the relevant authorities. This also applies to students who are already ill, have close contact with a high-risk family member, or are themselves infected.

The above-mentioned synchronous distance learning is implemented via a suitable digital platform that enables the real-time transmission (audio and/or video) of lessons by educators to their students. Private schools are allowed to choose an alternative digital platform that meets their specific needs and infrastructure. If a private school opts for a platform other than the one provided free of charge by the Ministry of Education and Religious Affairs, the school assumes responsibility for any related costs and for ensuring the platform complies with applicable regulations, particularly those concerning data protection under the General Data Protection Regulation (EU) 2016/679 and Law 4624/2019 (Government Gazette 137 A’).

The recording or storage of the audio and/or video of electronically transmitted lessons is strictly prohibited, as is any other use of electronically transmitted content beyond the live real-time transmission to students. For simultaneous synchronous distance learning, live transmission applies only to the portion of the lesson dedicated to teaching, and not to any part of the class related to student assessment or examination.

a) For audio transmission, the device must be securely placed near the educator. The educator reserves the right to mute a student or even terminate the transmission if deemed necessary.

b) For video transmission, the camera must focus exclusively on the educator and/or the classroom board. It is strictly prohibited to focus on students present in the classroom. The data controller, as defined by Article 4 of the General Data Protection Regulation (EU) 2016/679 (GDPR), is, for all private primary and secondary education institutions, the individual or legal entity, regardless of legal personality, that holds the operating license for the respective private educational structure.

Each data controller is required to appoint a Data Protection Officer in accordance with the provisions of the GDPR. If a private educational institution opts for a digital platform other than the one provided free of charge by the Ministry of Education and Religious Affairs, it must take all necessary measures to ensure compliance with current data protection regulations for members of the educational community. This includes ensuring that the platform’s design adheres to the principles of data protection by design and by default. The purpose of processing the aforementioned data is the public good of providing education during emergencies, such as the COVID-19 pandemic.

The lawful basis for processing such data is Article 6(1)(e) in conjunction with Article 6(1)(c) of the GDPR. Data subjects have the right to obtain confirmation from the data controller as to whether their personal data is being processed. They also have the right to access metadata generated using their actual information (e.g., email and full name for educators, full name for students) to enable identification. Furthermore, data subjects have the right to request corrections to inaccuracies and, under certain conditions, to object to processing by the Greek public or private entity licensed to operate the private educational structure, provided such objection is technically feasible. Complaints may be submitted to the Data Protection Authority.

The principal of each school unit is obligated to inform all educators, students, and parents/guardians in writing about the processing of their personal data exclusively for the purpose of distance learning. This notification must include the Ministry of Education and Religious Affairs' informational document, provided in either physical or electronic form.

The Ministry of Education and Religious Affairs, as the data controller for the personal data of students, parents/guardians, and teaching staff in public primary and secondary education structures, must comply with all obligations under the GDPR (EU) 2016/679 and the provisions of Law 4624/2019 (Government Gazette 137 A’). These obligations also apply to any individual or legal entity licensed to operate a private primary or secondary educational structure regarding the personal data of students, their parents/guardians, and the educators employed in such structures.