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GDPR Privacy Notice
This privacy notice provides information about the processing and the protection of your personal data.
Processing operation: Learn4dev online platform / Data Controller: Enabel
Introduction
This general privacy protection notice (hereinafter referred to as the ‘Notice’) aims to inform you comprehensively in this matter. It outlines how we collect, use and safeguard your personal data. Please take time to read this 'Notice' and become familiar with our practice in the matter. You can also find out more on the website of Belgium’s Data Protection Authority: www.dataprotectionauthority.be
As from 25/05/2018, the new Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (General Data Protection Regulation – ‘GDPR’), and repealing Directive 95/46/EC, is in force.
Scope of this 'Notice'
What is meant by ‘personal data’ and ‘processing’; what is the ‘personal data controller’ and who is the first person of contact or ‘DPO’? Personal data is information relating to an identified or identifiable natural person. This may, for instance, be the person’s name, a photo, a phone number, a code or password, a date of birth or an e-mail address.
Processing consists of any operation that is performed upon personal data, such as collection, recording, organisation, storage, adaptation or alteration, sorting, retrieval, consultation, use, disclosure by supply, dissemination or otherwise making available, alignment, combination, blocking, erasure or destruction of data.
Enabel, the Belgian development agency, with its registered office at Rue Haute 147, 1000 Brussels in Belgium, is the personal data controller for the learn4dev network. This means that we determine the purpose and means of processing the data and that we are the contact point for you or for the supervising authority for any question relating to the use of the data. Within our organisation we have appointed a single point of contact, the Data Protection Officer or DPO, who can be reached as follows: Enabel, Data Protection Officer, Rue Haute 147, 1000 Brussels, DPO@enabel.be
Whom does this concern? Our 'Notice' concerns natural persons such as members of the learn4dev network, forum/course participants, or third parties (for instance, a person who wants to be informed about our activities). On the other hand, legal persons are not concerned by this 'Notice'.
What data are collected by the learn4dev online platform?
In order to carry out this processing operation Enabel collects the following personal data from the different types of users registered or not registered on the learn4dev online platform:
a. Visitors to the platform (Guest access):
- IP address
b. Visitors who create a user account manually are required to provide the following data:
- Email address (required)
- First name (required)
- Surname (required)
- Type of organisation (required)
- Organisation (required)
- Position (required)
- Area of Expertise (required)
c. Users who are assigned as Learn4dev members are required to provide the following data:
- Email address (required)
- First name (required)
- Surname (required)
- Type of organisation (required)
- Organisation (required)
- Position (required)
- Area of Expertise (required)
- Area of Interest (required)
d. All registered users of the Learn4dev online platform have the option to provide the following data:
- City/town
- Country
- Description
- User picture
- Additional names
- Interests
- Other areas of interest
- Other: Web page, ICQ number, Skype ID, AIM ID, Yahoo ID, MSN ID, ID number, Institution Department, Phone, Mobile phone, Address.
When and how are your personal data collected?
Some of your personal data may be collected by Enabel:
- When you visit the learn4dev online platform, by means of cookies and other technologies (for more information on the cookies, please consult our Cookie Policy via the ‘Cookies’ button at the bottom of the page);
- When you create an account to log into the learn4dev platform;
- When you subscribe to the learn4dev newsletter;
- When you contact us through our email address;
- When you participate in an online course;
- When you participate in a discussion/forum;
- When you add or update information to your profile on the platform.
When we ask you for personal data, you have the right to not continue with the registration on the platform. Such refusal may however impede your full participation in the learn4dev platform.
We use your personal data when we have obtained your consent; in which case we process your personal data for the specific purpose(s) to which you have consented. This regards, for instance, your participation to the platform.
How do we protect your data?
Your personal data are accessed by those persons only for whom it is necessary for the fulfilment of their tasks. They are bound by strict professional discretion and must respect all technical and organisational prescriptions provided to ensure confidentiality of personal data.
We have put in place technical means to protect your personal data. We thus want to avoid that unauthorised persons can access, process, change or destroy them.
Sometimes the learn4dev online platform may provide links to other websites (social media, YouTube organisers of events that we support…) with conditions of use that may fall outside the scope of application of this 'Notice' and outside our responsibility. That is why we recommend that you always carefully read their Personal data protection notice to find out how they respect your privacy.
Who can access your data and to whom are they disclosed?
As the learn4dev online platform contains public discussions/forum, all the public can see the name and picture of the users who participate in the public discussions/forum.
Members of the learn4dev network are allowed to access the data of all registered users. These persons are staff members of the learn4dev member organizations:
- Agencia Española de Cooperación Internacional para el Desarrollo, AECID.
- Agence française de développement, AFD.
- Australian Government's Department of Foreign Affairs and Trade, DFAT.
- Austrian Development Agency, ADA.
- Kingdom of Belgium Foreign Affairs, Foreign Trade and Development Cooperation.
- Federal Ministry for Economic Cooperation and Development, BMZ.
- Global Affairs Canada, GAC.
- Center of Excellence in Finance, CEF.
- Ministry of Foreign Affairs of Denmark's International Development Cooperation, DANIDA.
- Government of the Netherlands' Development Cooperation.
- Enabel.
- Ministry of Foreign Affairs of Finland.
- Deutsche Gesellschaft für Internationale Zusammenarbeit, GIZ.
- Irish Aid, Department of Foreign Affairs and Trade.
- International Training Centre ITC-ILO.
- Norwegian Ministry of Foreign Affairs.
- Luxembourg Agency for Development Cooperation, LuxDev.
- Ministry of Foreign Affairs of the Republic of Poland.
- Ministry of Foreign Affairs of the Republic of Slovenia.
- Ministry of Finance of the Slovak Republic.
- New Zealand Foreign Affairs & Trade.
- Norwegian Agency for Development Cooperation, Norad.
- Sida.
- Swiss Agency for Development and Cooperation, SDC.
- UK's Department for International Development.
- Food and Agriculture Organization of the United Nations, FAO.
- International Organization for Migration, IOM.
- The European Commission’s department for International Cooperation and Development
- The World Bank.
- UN-Habitat.
- United Nations Development Programme, UNDP.
- United Nations System Staff College.
- World Food Programme, WFO.
- International Institute for Educational Planning of UNESCO, IIEP-UNESCO.
Members of the learn4dev network who act as administrators of the online platform are allowed to process your data. These persons are staff members of the learn4dev member organizations listed below:
- Deutsche Gesellschaft für Internationale Zusammenarbeit, GIZ.
- International Training Centre ITC-ILO.
- Luxembourg Agency for Development Cooperation, LuxDev.
- The European Commission’s department for International Cooperation and Development
We also disclose your data to other persons if we are bound to do so because of a contractual or legal obligation, or if a legitimate interest requires so. In such cases, we make sure that: These persons only dispose of data which we have to transfer following a contractual or legal obligation, or which are in proportion to the legitimate interest justifying the disclosure.
Enabel does not disclose your data to third parties for commercial use.
How long do we keep your personal data?
Enabel only keeps your personal data for the time necessary to fulfil the purpose of collection or further processing. The period of retention of data will depend on the period of activity within the learn4dev online platform.
What are your rights and how to exercise them?
Access rights: You have the right to access your data. You can ask us:
- Whether we process your data or not?
- For what purpose we process your data?
- What categories of data are being processed?
- What categories of recipients they are shared with?
- How long your data are stored?
- What rights you can exercise (rectification, deletion…) or what complaints procedures exist with the Data Protection Authority?
Right of rectification: If you find that notwithstanding our efforts your data are incorrect or incomplete, you can ask us to rectify them.
Right to erasure (‘right to oblivion’): In some specific cases, legislation allows you to have your personal data deleted. This applies particularly, if:
- The data are not needed any more for the purposes for which we have collected them;
- The processing of your data is solely based upon your consent and you have decided to withdraw such consent;
- You have opposed the processing of your data and there exists no legitimate grounds from our part prevailing over your legitimate interests.
Yet, your right to oblivion is not absolute. We have the right to continue to keep you data when such conservation is required for, among others:
- Compliance with a legal obligation;
- The substantiation, exercise or defence of legal rights.
Right to limit processing: In some specific cases, you can request to limit the processing of your personal data. This particularly applies,
- For the time needed for us to check your data, when you claim your personal data are not correct, and
- When your data are not needed any more for pursuing the purposes of the processing but are needed by you to substantiate, exercise or defend your rights in court.
Restrictions to processing will end in the following circumstances:
- You give us your approval in this respect;
- Your data need to be processed to substantiate, exercise or defend rights in court;
- Your data need to be processed to protect the rights of another natural or legal person;
- The processing is needed for reasons of public interest.
Transfer right: In some cases, you have the right to having your personal data which you have given to us:
- Transferred to you;
- Or, transferred directly by Enabel to another processing officer, provided this is technically possible.
This applies when,
- You have consented to having your data processed or the processing is required to execute a contract, and
- In case of automated processing.
Right to objection: When the processing of your personal data is based on a legitimate or general interest from our part, you have the right to object thereto at any time, for reasons related to your specific situation.
However, your request will not be considered if our legitimate interest appears to exceed your interest and if the processing of your data is required to substantiate, exercise or defend rights in court.
Right to revoke your consent: When processing by Enabel is based on your consent, you can at any time oppose (i) the processing of data for the above-mentioned purposes and (ii) the processing of personal data concerning your health. In such a case, Enabel possibly is unable to pursue the purpose and/or respond to your request for intervention. Such revoking will not change the legal status of the processing of your personal data carried in the period prior to your revoking consent.
Whom to address?
To exercise your rights, just send a request by mail or e-mail to our Data Protection Officer, via: Enabel, Data Protection Officer, Rue Haute 147, 1000 Brussels, e-mail: DPO@enabel.be
If you consider that the processing of your personal data is in breach of the privacy legislation, you can also file a complaint with the Data Protection Authority, via: Data Protection Authority, Rue de la Presse 35, 1000 Brussels, tel.: +32 2 274 48 00, e-mail: commission@privacycommission.be