Publication date: October 2020
Enabel takes your privacy serious.
We undertake to protect and process your personal data with due care, transparently and in strict compliance with privacy protection legislation. As from 25 May 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. We process your personal data in accordance with the GDPR.
This general privacy protection notice (hereinafter referred to as the ‘Notice’) aims to inform you comprehensively in this matter. It outlines how we, as personal data controller, collect, use and safeguard your personal data.
Please take time to read this Notice and become familiar with our practice in the matter.
Scope of this Notice
A. 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 which 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. 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:
Data Protection Officer
Rue haute 147
B. Whom does this concern?
Our Notice applies to all individuals who come into contact with Enabel or who visit our website, whether they apply for a job, with Enabel, are a service provider or a third party (for instance, a former staff member, a person who wants to be informed about our activities, a person who participates to an event organised by Enabel). On the other hand, legal persons are not concerned by this Notice.
C. What data are covered by this Notice?
When we interact with you and in function of the kind of contractual or other relation you have with Enabel, we may collect various personal data relating to you:
- identification data (such as name, first name, address or date of birth);
- contact data (such as postal address, e-mail address or telephone number);
- personal characteristics (such as a photo, language, nationality or date and place of birth);
education and training data (such as level of education, diplomas, qualifications or school career);
- career data (such as earlier and current employers or professional references);
personal competences (such as communication skills, organisational/management ability or proficiency with ICT tools);
- information on mental state (such as results of a psycho-technical personality test or data on leisure activities and interests);
- immigration status (such as the existence of a work permit that is valid in Belgium);
assessment of the recruiter regarding your professional capacities and your personality;
- national registry number, VAT number;
- behaviour data, namely data regarding your use of the website (such as preferred language, cookies or activity journals);
- connection information, i.e. information that we collect when you connect to our website (such as IP address or information on the device);
- photos or videos.
When and how are your personal data collected?
Some of your personal data may be collected by Enabel:
- When you fill out your data online in view of applying for a job with Enabel, and, where applicable, when you participate in a recruitment procedure (video interview, face-to-face meeting, personality test/ technical skills test, etc.);
- When you participate to and/or execute a public contract with Enabel;
- When you subscribe to one of our newsletters, answer one of our invitations (for conferences, events…), etc.;
- When you participate to the events that we organise;
When you contact us through one of the many channels made available to you by Enabel (such as online contact forms to request information or file a complaint, e-mail, telephone, social media and others);
When we ask you for personal data, you have the right to refuse to respond. Such refusal may however impede the emergence of contractual relations, change the nature thereof or affect their management.
On what basis and for what purposes will your data be processed?
We use your data for different purposes, which we detail below. For each processing, only the relevant and necessary data for pursuing the purpose in question are processed. In addition, we undertake to process your personal data only in a manner consistent with the purposes for which they were originally collected.
We collect your data for the following purposes:
- Processing your request, application, or complaint: When you send us a request and you share your contact information with us for this purpose (whether through our contact or complaint forms on our website or any other communication channel), we use your data to respond to your request by contacting you. We then process your identification and contact data, as well as the content of your message, because you consent to it by sending us your request. We only use this information to deal with your question or complaint to the extent needed.
- Processing your application for a job at Enabel’s: If you submit your application to us, you consent to us processing your identification and contact data, your personal characteristics, information about your education and training, your professional data (including in your CV and motivation letter), your immigration status, information about your personal skills and mental state, as well as the recruiter's assessments and evaluations regarding your professional abilities and personality, for recruitment purposes and in particular to:
- Allow you to submit your CV or apply online;
- Assess your application against our vacancies;
- Contact you and answer your application (or any questions);
- Arrange interviews;
- Perform skills or personality tests;
- Offer you other opportunities for positions similar to the one you are applying for;
- Prepare your employment contract to offer you a position.
We process your personal data because you have consented to it by submitting your application to us. You can edit or cancel your application online at any time via your online account.
We draw your attention to the fact that, for our recruitment process, we do not need to collect sensitive data about you, such as data revealing your race or ethnic origin, your political, religious or philosophical opinions, your union membership, your health or your sex life. Be aware that if you choose to provide us with unsolicited sensitive data spontaneously (for example in your motivation letter or during the interview), you do so under your own responsibility and we will not take it into account during the recruitment process.
- Sending newsletters: When you sign up for our newsletters to be kept informed of our activities, we collect your e-mail address in order to send you our newsletters. We are sending it because you have consented to it. If you no longer wish to receive our newsletters, you can withdraw your consent at any time, via the link built directly into each newsletter.
- Managing our events: When you sign up for and participate in one of the events we host, we process some of your personal data based on your consent and our legitimate interest in managing/organising our events. Specifically, we process your data in this context to:
- Manage and count participants at our events
- Contact you in relation to the event you are attending
- Use photos and videos in which you might appear as background images to promote the event and its future editions and post them on our website, intranet, social media and brochures. The photographs and footage will never be transferred to third parties for commercial purposes.
- When registering online for our events, you have the option to indicate in advance that you do not want to be photographed or filmed in a targeted manner and/or that you do not want that these photos or videos in which you are clearly recognisable are used by Enabel. If, however, a photo or video in which you appear clearly were to be published by Enabel, you have the right to request the removal of these photos or videos. You can do this by sending an e-mail to firstname.lastname@example.org with your name, first name and name of the event you participated in, as well as the indication of the photo or video in question (link or reference). It will be removed from online posts as soon as possible and in accordance with what is technologically possible.
- Public Procurement management: When you participate to and/or execute a public contract with Enabel, we collect contact information from our suppliers and partners such as name, first name, professional telephone number, professional e-mail address and workplace address, name of the organisation represented (if any), but also VAT number or national registry number (if the person is not in company). If necessary, we also collect the CV as well as the criminal record and tax status of the supplier, partner or person representing them. We process this information because we have a legal obligation to collect this information as part of our public procurement management.
- Award and management of our grants: When you participate in a call for proposals as part of Enabel's grant allocation, we collect contact information (‘authorised representative’) of the entity submitting the grant application, such as name, first name, business telephone number, professional e-mail address, job title and name of the organisation represented. We process this information because we have a legal obligation to collect this information as part of our grant award management.
- Social media presence: Enabel has a corporate page on various social networks, such as namely Facebook, Instagram, LinkedIn, Twitter and Youtube. These pages are used to inform you about our news and, if so, contact you if you ask us a question via e-mail or comments. If you send us personal data via a social network's messaging, it is only used to answer your question or to follow up on your request. We then process your personal data based on our legitimate interest in communicating with visitors to our page.
We also use the statistical reporting function provided by social networks (such as "Facebook Insights") in relation to the operation of our corporate pages to obtain anonymous statistical data about users, for example, about "likes" on our Facebook page, the visibility of our posts and the demographics of visitors to the page. This data processing is intended to allow us, as the operator of the company page, to receive statistics compiled by the social network from visits to our company page. The aim is to monitor the visibility of our activities. Visitor statistics are transmitted exclusively to us in anonymous form. We do not have access to the underlying datasets.
We also draw your attention to the fact that when you visit our corporate social network page, cookies are usually installed, by the social network in question, on your device. These cookies record your browsing behaviour and interests. The personal data collected by these cookies are then used for statistical analysis and marketing purposes (in order to provide you with targeted advertisements that are supposed to match your interests). Enabel has no control or access to the personal data collected by the various social networks. We have no influence on how your personal data is handled by social networks. Therefore, we would like to point out to you that for any questions relating to the processing of your data by these social networks or to exercise your rights in relation to your data, you must turn to the social network concerned. Indeed, only the social network has direct access and control over the personal data collected through the use of our pages, and can therefore take the necessary measures. For more information about the processing of your personal data by the various social networks, please consult the privacy notices of these social networks or contact the social network concerned directly.
How do we protect your data?
We undertake to maintain the privacy and security of your personal data. To do this, we have put in place technical and organisational security measures to prevent the destruction, loss, tampering, tampering, unauthorized access or disclosure of your personal data to third parties and any other unauthorised processing of these data.
We have made every effort to ensure the confidentiality, integrity and availability of information systems and services that process personal data. These include physical and operational security measures, access control, awareness and confidentiality clauses. 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 our websites may provide links to other websites (social media, 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?
A. General remarks
In order to protect your privacy, staff members of Enabel who are allowed to access your data are selected with care in function of their tasks.
Enabel also uses subcontractors, which are specialised partners in Belgium or abroad, which we rely on for certain services in view of improving the quality of our services.
These are, among others, external recruitment bureaux, selection committee members as well persons involved in recruitment procedures in accordance with internal rules, the HR services company/salary software, the HRIS system, the mobile phone operator, the social security instances, the fiscal administration, the insurance companies, the training instances, the ICT service providers, lawyers, or provincial partners of our Global Citizenship Education programmes.
These subcontractors are contractually bound to us and must, as a consequence, follow our instructions and respect the principles laid down in our Notice.
Enabel particularly ensures that its subcontractors:
- Only have the data which they need to exercise their tasks; and
- Commit vis-à-vis Enabel, on the one hand, to process these data in a secure and confidential manner, and on the other hand, to only use them for the execution of their tasks.
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;
- These persons commit vis-à-vis Enabel, on the one hand, to process these data in a secure and confidential manner, and on the other hand, to only use them for the purpose for which the data have been disclosed to them.
B. No disclosure for commercial use
Enabel does not disclose your data to third parties for commercial use.
C. Disclosure outside the European Economic Area (EEA)
Because it operates in the partner countries of the Belgian Development Cooperation, Enabel is likely to disclose your data outside the European Economic Area (EEA), in a country which may fail to provide an adequate level of protection of personal data. But in this case, we guarantee appropriate safeguards that ensure that your rights are also respected by the recipient of the data outside the EEA, in accordance with an adequate level of data protection.
How long do we keep your personal data?
We keep your data during the legally prescribed period or any other retention period that would be required by law.
If the law does not prescribe a specific retention period, we determine the time frame on the basis of the objective for which the data was collected. We do not keep your data longer than necessary to achieve the goal.
Finally, when your data are collected on the basis of your consent, we only use it until you withdraw your consent.
We guarantee that we will give only limited access to the archived data and that your personal data will be deleted or made anonymous if the retention period has passed.
Regarding applications for a position with Enabel, if your application is successful and results in an employment relationship, your personal data collected as part of the recruitment process will be transferred to your personal employee file and kept for the duration of your employment contract, and beyond, for periods determined by law, and specified in our Employee Confidentiality Notice.
If your application is not successful, we will keep your data in a applicants’ reserve database for up to 3 years after the end of the recruitment process, with a view to being able to contact you in the case another position corresponding to your application is opening up.
What are your rights and how to exercise them?
In accordance with privacy legislation, you have, under certain conditions, well defined in said legislation, several rights regarding your personal data:
A. 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?
- Where the processed data originate from?
B. Right of rectification
If you find that notwithstanding our efforts your data are incorrect or incomplete, you can ask us to rectify them.
C. 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.
D. Right to limit processing
In some specific cases, you can request to limit the processing of your personal data. We will continue to store your data, but we will limit their use.
This particularly applies when,
- 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.
E. 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.
F. 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.
G. Right to revoke your consent
When processing by Enabel is based on your consent, you can at any time revoke your consent. 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 your dated and signed request, with a recto copy of your identity card, by mail or e-mail to our Data Protection Officer, via:
Data Protection Officer
Rue Haute 147
These rights are free of charge and can be exercised at any time. We undertake to respond to your request within one month of receiving it.
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
Tel.: +32 2 274 48 00
How do I get informed of changes to this privacy notice?
Enabel may amend or update this privacy notice from time to time to reflect changes in our practices regarding the processing of your personal data or changes to applicable laws. To do this, we post the updated version on our website. We invite you to check out the latest online version of this notice on a regular basis. The date of the most recent changes is given on said page.
How to contact us about this privacy notice?
If you have any questions regarding the processing of your personal data or any comments related to this privacy notice, please contact our Data Protection Officer:
- Either in a letter sent to: Enabel / Data Protection, Rue Haute 147, 1000 Brussels,
- Or else by e-mail to the following address: DPO@enabel.be