Privacy policy

This website is published in the framework of the VET Toolbox project, Promoting Inclusive, Demand-Driven VET & Skills Development, an action co-funded by the European Union under Development Cooperation Instrument and by the German Government.

This website is hosted and managed by Enabel, the Belgian development agency, considered as the personal data controller, in partnership with the Coordination HUB of the VET Toolbox project located at Enabel.

Enabel and the Coordination HUB of the VET Toolbox project 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. We also invite you to take the time to read Enabel’s General Privacy Statement on which this statement is based. You can access it on the following link: https://www.enabel.be/en/content/title-1. 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.

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.

Our Notice concerns natural persons such as applicants requesting for expertise and/or people requesting for information from the VET Toolbox project.

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 and the Coordination HUB of the VET Toolbox project, 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.);
• payment data, particularly your bank account number;
• qualifications, CVs and references in particular;
• information on training attended or scheduled;
• information on personal development and evaluations;
• 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.

Some of your personal data may be collected by Enabel and the Coordination HUB of the VET Toolbox project:

• When you fill out your data on-line in view of applying for a job with Enabel and the Coordination HUB of the VET Toolbox project;
• 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 and the Coordination HUB of the VET Toolbox project;
• 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 and the Coordination HUB of the VET Toolbox project (to request information or file a complaint, for instance);
• When you visit one of our websites or when you use one of our mobile applications, by means of cookies and other technologies (for more information on the cookies, please consult our Cookie Policy on www.enabel.be) (via the ‘Cookies’ button at the bottom of the page).

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.

Enabel and the Coordination HUB of the VET Toolbox project processes your 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;
• Managing our public procurement contracts: – managing of tenders, performance of public procurement contracts;
• To monitor actions of the VET Toolbox;
• To exchange information with requestors.

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.

Technical and content managers of this website have signed an ethical and confientiality charter specifying their obligations of strict confidentiality and discretion when conducting its controlling tasks in view of having the ICT services function properly and more in particular when conducting its surveillance and personal, professional or private data control tasks.

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.

In order to protect your privacy, staff members of Enabel and the Coordination HUB of the VET Toolbox project who are allowed to access your data are selected with care in function of their tasks.

Enabel and the Coordination HUB of the VET Toolbox project also uses subcontractors, which are specialised partners in Belgium or abroad, providing certain services in view of improving the quality of our services.

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 and the Coordination HUB of the VET Toolbox project particularly ensures that its subcontractors only have the data which they need to exercise their tasks, and commit vis-à-vis Enabel and the Coordination HUB of the VET Toolbox project, 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 and the Coordination HUB of the VET Toolbox project, 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 and the Coordination HUB of the VET Toolbox project does not disclose your data to third parties for commercial use.

Because it operates in the partner countries of the Belgian Development Cooperation, Enabel and the Coordination HUB of the VET Toolbox project is likely to disclose your data outside the European Economic Area (EEA). Enabel and the Coordination HUB of the VET Toolbox project takes every necessary measure to ensure data protection by strengthening its information security.

A cookie is a piece of information in the form of a very small text file that is placed on the hard drive of an internet user’s device. Cookies are not active executable programs and consequently pose no risk to your system.

Enabel.be uses cookies to optimise your browsing experience and adapt its website to your desires and preferences. You may refuse these cookies to be installed, yet in that case certain features may be limited or unavailable.

If you further pursue your visit to our website without changing your cookies configuration or without explicitly accepting cookies, we consider the installation of cookies to be accepted by you.

The cookies used by Enabel are not of a commercial nature and register no personal data. The cookies are used for facilitating your browsing experience. A visit will consequently not require personal parameters such as language, screen parameters, a login… to be given upon every visit.

The cookies (Google Analytics) are also used to monitor web surfing habits of users, pages visited and frequency of visits, how the site is found and how much time is spent on the site. Based on this information the website may be adapted to better respond to the interests and needs of its users for instance by providing useful customized information.

• Functional cookies: These cookies can retain user preferences for a particular website, allowing those preferences to be used in future browsing sessions.
• Analytical cookies: These cookies are used to measure the user’s browsing experience, via which channels the site attracts its users, which search terms are used when browsing the site, etc.

Do you want to change the configuration of the cookies, or delete them? That is possible. Click on the link to find out how: https://www.aboutcookies.org/.

Enabel and the VET Toolbox shall collect and process the personal data of requestors for the purpose of the processing of the request form. The processing may also be carried out electronically. This is the case, in particular, if a requestor submits corresponding request documents by e-mail or by means of a web form on the website to the controller. The data collected thanks to the request form (online and/or on paper) can be used by Enabel and the VET Toolbox in order to monitor and promote actions online and offline (e.g. publication of fact sheets, articles and any other promotional material relevant to the promotion of the VET Toolbox project) supported in the frame of the VET Toolbox project.

On this website, users are given the opportunity to subscribe to the VET Toolbox’s newsletter. The input mask used for this purpose determines what personal data are transmitted, as well as when the newsletter is ordered from the controller.

We inform our target audiences and partners regularly by means of a newsletter about the VET Toolbox progress. The VET Toolbox’s newsletter may only be received by the data subject if (1) the data subject has a valid e-mail address and (2) the data subject registers for the newsletter shipping. A confirmation e-mail will be sent to the e-mail address registered by a data subject for the first time for newsletter shipping, for legal reasons, in the double opt-in procedure. This confirmation e-mail is used to prove whether the owner of the e-mail address as the data subject is authorized to receive the newsletter.

During the registration for the newsletter, we also store the IP address of the computer system assigned by the Internet service provider (ISP) and used by the data subject at the time of the registration, as well as the date and time of the registration. The collection of this data is necessary in order to understand the (possible) misuse of the e-mail address of a data subject at a later date, and it therefore serves the aim of the legal protection of the controller.

The personal data collected as part of a registration for the newsletter will only be used to send our newsletter. In addition, subscribers to the newsletter may be informed by e-mail, as long as this is necessary for the operation of the newsletter service or a registration in question, as this could be the case in the event of modifications to the newsletter offer, or in the event of a change in technical circumstances. There will be no transfer of personal data collected by the newsletter service to third parties. The subscription to our newsletter may be terminated by the data subject at any time. The consent to the storage of personal data, which the data subject has given for shipping the newsletter, may be revoked at any time. For the purpose of revocation of consent, a corresponding link is found in each newsletter. It is also possible to unsubscribe from the newsletter at any time directly on the website of the VET Toolbox, or to communicate this to the data controller.

The newsletter contains so-called tracking pixels. A tracking pixel is a miniature graphic embedded in such e-mails, which are sent in HTML format to enable log file recording and analysis. This allows a statistical analysis of the success or failure of online marketing campaigns. Based on the embedded tracking pixel,we may see if and when an e-mail was opened by a data subject, and which links in the e-mail were called up by data subjects.

Such personal data collected in the tracking pixels contained in the newsletters are stored and analyzed by the controller in order to optimize the shipping of the newsletter, as well as to adapt the content of future newsletters even better to the interests of the data subject. These personal data will not be passed on to third parties. Data subjects are at any time entitled to revoke the respective separate declaration of consent issued by means of the double-opt-in procedure. After a revocation, these personal data will be deleted by the controller. We automatically regards a withdrawal from the receipt of the newsletter as a revocation.

On this website, the controller has integrated components of YouTube. YouTube is an Internet video portal that enables video publishers to set video clips and other users free of charge, which also provides free viewing, review and commenting on them. YouTube allows you to publish all kinds of videos, so you can access both full movies and TV broadcasts, as well as music videos, trailers, and videos made by users via the Internet portal.

The operating company of YouTube is YouTube, LLC, 901 Cherry Ave., San Bruno, CA 94066, UNITED STATES. The YouTube, LLC is a subsidiary of Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, UNITED STATES.

With each call-up to one of the individual pages of this Internet site, which is operated by the controller and on which a YouTube component (YouTube video) was integrated, the Internet browser on the information technology system of the data subject is automatically prompted to download a display of the corresponding YouTube component. Further information about YouTube may be obtained under https://www.youtube.com/yt/about/. During the course of this technical procedure, YouTube and Google gain knowledge of what specific sub-page of our website was visited by the data subject.

If the data subject is logged in on YouTube, YouTube recognizes with each call-up to a sub-page that contains a YouTube video, which specific sub-page of our Internet site was visited by the data subject. This information is collected by YouTube and Google and assigned to the respective YouTube account of the data subject.

YouTube and Google will receive information through the YouTube component that the data subject has visited our website, if the data subject at the time of the call to our website is logged in on YouTube; this occurs regardless of whether the person clicks on a YouTube video or not. If such a transmission of this information to YouTube and Google is not desirable for the data subject, the delivery may be prevented if the data subject logs off from their own YouTube account before a call-up to our website is made.

YouTube’s data protection provisions, available at https://www.google.com/intl/en/policies/privacy/, provide information about the collection, processing and use of personal data by YouTube and Google.

The data controller shall process and store the personal data of the data subject only for the period necessary to achieve the purpose of storage, or as far as this is granted by the European legislator or other legislators in laws or regulations to which the controller is subject to.

If the storage purpose is not applicable, or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data are routinely blocked or erased in accordance with legal requirements.

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?

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 and the Coordination HUB of the VET Toolbox project 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 and the Coordination HUB of the VET Toolbox project 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 and the Coordination HUB of the VET Toolbox project 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.

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: commission@privacycommission.be.