13 JUNE 2022
1. PURPOSE OF THE DATA PROTECTION POLICY
The purpose of this EACB Consolidated Data Protection Policy is to explain in a clear and simple way the processing made by the EACB on the personal data of persons external to the EACB (e.g. staff member to the EACB members, subcontractors, visitors to the EACB website or social network pages, ...).
This Data Protection Policy is regularly updated. We invite you to regularly consult our website to consult the current version. This Data Protection Policy is also always accessible at the EACB's headquarters (Rue de l’Industrie 26-38, B-1040 Brussels).
2. GENERAL INFORMATION APPLICABLE TO ANY PERSONAL DATA PROCESSIN
2.1. Who is processing your data?
The European Association of Co-operative Banks AISBL (hereinafter "EACB" or “We”), an international non-profit organisation with registered office at rue de l'Industrie 26-38, 1040 Bruxelles and registered with the Crossroads Bank of Enterprises under number BE 0896.081.149, is responsible for the processing of your personal data (“data controller” within the meaning of the GDPR).
If you have any questions or requests in relation to this Data Protection Policy, please feel free to contact us by post at the above-mentioned address or by email at the following address: secretariat@eacb.coop.
If you would like more information, or if you wish to lodge a complaint, you can contact the Data Protection Authority (Rue de la Presse, 35 - 1000 Brussels, Tel. + 32 2 274 48 00 - contact@apd-gba.be ; https://www.autoriteprotectiondonnees.be/citoyen/agir/introduire-une-plainte).
2.2. As a data subject, what are your rights?
The following section explains your rights under GDPR.
Information - You have the right to be provided with clear, transparent and intelligible information about how We use your personal data and your rights. This right is exercised through this document. If the data processed includes data of your staff, you are responsible for making them aware of this document.
Access and rectification - You have the right to access your data and to have them rectified if necessary.
You have the right to consult your data at any time and free of charge, by sending an email to secretariat@eacb.coop or a dated and signed letter to EACB headquarters (Rue de l’Industrie 26-38, B-1040 Brussels). You also have the right to demand that incorrect data be corrected and that inappropriate or unnecessary data be deleted by sending an email to secretariat@eacb.coop or by sending us a dated and signed letter to the address of the EACB headquarters (Rue de l’Industrie 26-38, B-1040 Brussels).
Opposition - You may object to the processing of your data by EACB on the basis of our legitimate interest. You will be able to exercise your right to object through the unsubscribe links available in the e-mails sent to you or you can directly object by sending an email to EACB (secretariat@eacb.coop).
Withdrawing your consent - Where data is processed on the basis of your consent, you may withdraw this consent at any time, without calling into question the past processing.
Erasure - You may obtain the erasure of your data or the restriction of processing under the conditions set out in GDPR articles 17 and 18.
Portability - The data you have provided to us may be communicated or transmitted in electronic format.
2.3. Is your data transferred outside the European Union?
As a general rule, your data are exclusively stored on servers located inside the European Union.
However, in the event of transfer outside the European Union, your personal data can potentially be sent to non-EU countries for whom the European Commission has not established an “adequacy decision”. In such cases, We ensure that this transfer is carried out in accordance with the applicable regulations and We ensure a sufficient level of protection of individuals’ privacy and fundamental rights (mainly through the European Commission’s standard contractual clauses and supplementary measures).
3. SPECIFIC DATA PROCESSING DEPENDING ON YOUR QUALITY
3.1. You are an EACB member or a staff member of an EACB member
Categories of data collected - If you are a staff member of an EACB member, the following personal data about you may be processed: identification data (last name, first name), contact data (e-mail address, telephone number), professional data (organisation, position).
Purpose(s) and legal basis - These personal data are processed for the following purposes:
- Coordination, communication and meetings with the EACB members. the EACB has a legitimate interest in coordinating the relation with its members and to keep them informed of the AISBL’s activities.
Retention period - Your data are kept until you ask us to delete it. You can also update or delete your personal data at any time by contacting us (secretariat@eacb.coop).
Recipients - In order to accomplish the purposes listed above, your data may be communicated to the following recipients:
- The EACB's staff members (employees, freelancers, trainees, etc.) as well as its partners, if the processing of your data is necessary for the performance of their tasks;
- The EACB's subcontractors, processing personal data on behalf of the EACB.
3.2. You are a supplier of the EACB
Categories of data collected - If you provide services/products to the EACB, the following personal data about you may be processed: identification data (last name, first name), contact data (e-mail address, telephone number), professional data (company, position), financial/accounting information (bank account number, account holder), service tracking data.
Purpose(s) and legal basis – These personal data are processed for the following purposes:
- For the purpose of managing the contractual relationship: management of orders, offers, delivery, invoicing and payment and evaluation of the supplier's performance (if any). This processing is necessary for the proper execution of the contract concluded between you and the EACB. Without these data, the EACB cannot execute the contract.
- In order to ensure the security of the EACB's infrastructures to which you have access in the context of the mission entrusted to you, your data may also be processed. This processing is justified by the EACB's legitimate interest in ensuring the security of its offices.
Retention period - Your data are kept for 10 years after the end of the last contract with the EACB.
Recipients - In order to accomplish the purposes listed above, your data may be communicated to the following recipients:
- The EACB's staff members (employees, freelancers, trainees, etc.) as well as its partners, if the processing of your data is necessary for the performance of their tasks;
- The EACB's subcontractors, processing personal data on behalf of the EACB.
3.3. You are a visitor of the EACB website
Categories of data collected - If you visit the EACB’s website (eacb.coop), you do not have to provide any personal data. However, the provision of the websites involves the collection of "cookies" (for more detailed information, see our Cookies Policy available on our website).
If you subscribe to our newsletters and/or if oy contact the EACB via the "Contact Us" form on the website, the following personal data about you may be processed: identification data (name, surname), contact data (e-mail address), professional data (your company), any other information you include in your message (where relevant).
Purpose(s) and legal basis - These personal data are processed for the following purposes:
- For the purpose of placing and reading cookies: some cookies are necessary to enable navigation on the websites while others are optional and you are free to accept them or not. For more information, see our Cookie Policy.
- When you subscribe to our newsletters service: to send you our newsletters, including to keep you informed of our upcoming events, trainings, news and publications. The collection and processing of your personal data is based on your consent.
- When you send us a message via the contact form: to manage your request and respond to your request. The collection and processing of your personal data is based on your consent.
Retention period - Your personal data shall be stored/ processed:
- Regarding the cookies: see our Cookie Policy for more detailed information.
- When you subscribe to our newsletters service: as long as you keep your newsletters subscription active (withdrawal of your consent being possible at any time by unsubscribing) or until the EACB decides to terminate its newsletters service.
- When you send us a message via the contact form: until your request has been processed.
Recipients - In order to accomplish the purposes listed above, your data may be communicated to the following recipients:
- The EACB’s staff members (employees, freelancers, trainees, etc.) and its partners, if the processing of your data is necessary for the performance of their tasks;
- The EACB's subcontractors, processing personal data on behalf of the EACB;
- To any third parties mentioned in the Cookie Policy.
3.4. You are a visitor of a EACB social media page
Categories of data collected - If you visit the EACB's social media pages (namely Twitter, LinkedIn and YouTube), the following personal data may be processed jointly by the relevant social media and the administrator of that page: data related to your account, data related to the sharing of content or communications you have with others.
Purpose(s) and legal basis - These personal data are processed for the following purposes:
- Your data may be processed by the administrator of the page (EACB) in the context of its legitimate interest to obtain statistics on the visitors of his page in order to adequately promote his page. The statistics of audience established by the social media are only transmitted to the administrator of the page in an anonymized form.
Retention period - Your data are or could be processed as long as the page exists and you visit it.
The Privacy Policies of each social network used by the EACB can be found by clicking on the following links:
- Twitter,
- Linkedin,
Recipients - In order to accomplish the purposes listed above, your data may be communicated to the following recipients
- The EACB's staff members (employees, freelancers, trainees, etc.) as well as its partners, if the processing of your data is necessary for the performance of their tasks;
- The EACB's subcontractors, processing personal data on behalf of the EACB;
- The relevant social network.
3.5. You participate in an event organized by the EACB
Categories of data collected - If you register to an event organised by the EACB, the following personal data concerning you may be processed: identification data (surname, first name,), contact data (e-mail address, business postal address, telephone number), professional data (position, company). If you consent, we may also use your image.
Purpose(s) and legal basis - These personal data are processed for the following purposes:
- When you register for one of our (offline or online) event) it is necessary that you fill in a registration form. The data you provide when filling in this form is processed by EACB for the purpose of organising and following up the event. Without it, we cannot sign you up for the event and provide you with the information on such an event. The processing of your personal data is necessary for the performance of the contract between us in the context of the event to which you have subscribed.
- We may also process your data to promote our events (including the sharing of the recordings/images to participants who want to rewatch the event or people who were not able to attend the event). In this case, your data are processed on the basis of our legitimate interest in promoting our services to the public.
- Where applicable, your image may be processed on the basis of your consent: to reproduce, store stream or communicate audio recordings, photos, videos, images and publish photos, audio recordings or videos where you may appear to report on activities, and to promote activities organized by the EACB on the EACB website and extranet, social medias, newsletters or in any other EACB publications.
Retention period - Your data are processed for a maximum period of 5 years from the date of the event you participated unless you object to the processing or withdraw your consent.
Recipients - In order to accomplish the purposes listed above, your data may be communicated to the following recipients:
- The EACB's staff members (employees, freelancers, trainees, etc.) as well as its partners, if the processing of your data is necessary for the performance of their tasks;
- The EACB's subcontractors, processing personal data on behalf of the EACB;
- The public via EACB’s website and social media accounts.
3.6. You apply for a job, an internship or a temporary post
Categories of data collected - If you apply for a job/internship/interim position at the EACB, the following personal data may be processed: identification data (name, surname, image, date of birth), contact data (e-mail address, postal address, telephone number), data related to your professional background (experience, CV, previous employers, language skills, etc.), data related to the interview and to the job questionnaire (evaluation, comments), previous or alleged remuneration, and, in exceptional cases, sensitive data, and any information contained in your curriculum vitae and/or covering letter.
Purpose(s) and legal basis – These personal data are processed for the following purposes:
- To evaluate your application: the EACB examines your application in order to assess the possibilities of a contractual relationship.
- For security purposes: For certain jobs or projects, the EACB may ask you to provide certain sensitive data. In this case, the EACB's legitimate interest in hiring trusted individuals to ensure the security of its activities allows it to process this type of data.
- For the purpose of building up a recruitment reserve: the EACB’s legitimate interest is to contact you at a later date regarding the job offer in the event that the person initially recruited withdraws or in the event of a vacancy for another similar position that is immediately available. If you do not wish to be included in the recruitment pool, you may always object.
Retention period - If your application is unsuccessful, your data is automatically deleted 6 months the end of the selection process.
Recipients - In order to fulfill the purposes listed above, your data may be communicated to the following recipients:
- The EACB's staff members (employees, freelancers, trainees, etc.) as well as its partners, if the processing of your data is necessary for the performance of their tasks;
- The EACB's subcontractors processing personal data on behalf of the EACB.
4. IN ANY CASE
In any case, the EACB can process your personal data in the following cases:
4.1. Possible legal dispute
Your personal data may be processed for the purpose of managing any dispute that may arise between you and the EACB. In this case, the EACB has a legitimate interest to process your personal data to exercise its legal rights.
The EACB may also process sensitive data (special categories of personal data), where this is necessary for the establishment, exercise or defense of its legal rights in accordance with the provisions of Article 9 §2, f. of the GDPR.
For the fulfillment of this purpose, your personal data may be communicated to the following recipients:
- Members of the EACB's staff (employees, freelancers, trainees, etc.) as well as its partners, if the processing of your data is necessary for the performance of their tasks;
- To EACB's lawyers, consultants, collection companies, bailiffs;
- To police and/or judicial institutions;
- To EACB's subcontractors, processing personal data on behalf of the EACB.
4.2. Prevention of fraud and abuses
Your data may be processed to combat fraud and abuse (only for processing involving a contract between you and the EACB): the EACB is under a legal obligation to carry out certain checks relating to the reputation and solvency of its contracting parties, in order to guard against the risks of fraud and abuse.
For this purpose, your data may be communicated to the following recipients:
- Members of the EACB's staff (employees, freelancers, trainees, etc.) as well as its partners, if the processing of your data is necessary for the performance of their tasks;
- To EACB's lawyers, consultants, collection companies, bailiffs;
- To police and/or judicial institutions;
- To EACB's subcontractors, processing personal data on behalf of the EACB;
- To authorities, public bodies, carrying out controls.
4.3. Direct marketing
Your identification data (name, first name), professional data (company, function, country, sector of activity), contact data (e-mail, language of communication) may be processed by the EACB for direct marketing purposes:
- If you have already registered for one of the events organized by the EACB, the EACB has a legitimate interest to promote its activities (to inform people about upcoming events, news and publication). However, you have the right to object to the processing of your data at any time.
- If you give your consent, your personal data may be processed for the purpose of sending you direct marketing (e.g. via our newsletter service). You can withdraw your consent at any time.
For this purpose, your data may be communicated to the following recipients:
- the EACB's staff members (employees, freelancers, trainees, etc.) as well as its partners, if the processing of your data is necessary for the performance of their tasks;
- the EACB's subcontractors, processing personal data on behalf of the EACB.