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.
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 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:
Enabel, Data Protection Officer, Rue Haute 147, 1000 Brussels, DPO@enabel.be
Whom does this concern?
Our Notice concerns natural persons such as applicants searching employment with Enabel, members of staff, service providers or third parties (for instance, former staff member or 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 covered by this Notice?
a) Non-specific categories of personal data
The data in this category are personal data about you, i.e. data through which you can be identified either directly (data such as your name and first name allow us to identify you immediately) or indirectly (data such as your phone number or your car’s licence plate by which you can be identified indirectly).
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, date of birth, passport number, nationality, etc.);
- contact data (such as postal address, e-mail address, telephone number, etc.);
- marital status and information about your partner and children;
- payment data, particularly your bank account number;
- social security number, national registry number, VAT number;
- information on absences, including incapacity for work;
- qualifications, CVs and references in particular;
- information on training attended or scheduled;
- information on personal development and evaluations;
- medical certificates on one’s health state;
- vaccination status;
- ID photo.
In some cases, personal data are not solely relating to you, but also to one or more of your relatives (for instance, your children or partner).
b) Special categories of personal data
Personal data that are specifically protected are those falling under the ‘special categories’. These are personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, and genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation.
In practice, Enabel may process data concerning your health or the health of a member of your family in view of, for instance, medical repatriation for providing health care. This may also concern the degree of disability of a child, considering that Enabel pays its expatriate staff an equivalent of the Belgian family allowances.
Likewise, when you are hired as an expatriate, Enabel asks you for an extract from the criminal records.
In no case shall Enabel use your data falling under the special categories for other purposes.
When and how are your personal data collected?
Some of your personal data may be collected by Enabel:
- When you fill out your data on-line in view of applying for a job with Enabel;
- When you are recruited for a job opening and you sign an employment contract;
- When you participate to and/or execute a public procurement contract with Enabel;
- When you subscribe to one of our newsletters, answer one of our invitations (for conferences, events…), etc.;
- When you contact us through one of the many channels made available to you by Enabel (to request information or file a complaint, for instance);
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?
Enabel processes your data for various purposes
We process your personal data for various purposes. For each processing, only the relevant data for pursuing the purpose are processed.
We use your personal data either:
- 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 subscription to our newsletters in view of being informed about our activities;
- the pre-contract phase and for employment contract execution:
- recruitment and selection for a job opening;
- administration of remuneration, of allowances, social advantages, absences and insurance of an employee;
- purchasing of travel tickets (e.g. flight ticket) and obtention of visa;
- managing our public procurement contracts:
- managing of tenders, performance of public procurement contracts.
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 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?
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, providing certain services in view of improving the quality of our services.
These are external recruitment bureaux, selection committee members as well as 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, the 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.
Enabel does not disclose your data to third parties for commercial use.
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). Enabel takes every necessary measure to ensure data protection by strengthening its information security.
What are your rights and how to exercise them?
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?
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.
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 your dated and signed request, with a recto-verso copy of your identity card, 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: firstname.lastname@example.org