Key principles of data processing

AESGP is committed to handling personal data in compliance with applicable data protection laws, including 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 (the so-called “GDPR”). Specifically, AESGP commits to processing personal data according to the following principles:

• Lawfulness, transparency and fairness;
• Purpose Limitation;
• Data Minimisation;
• Accuracy;
• Storage limitation;
• Confidentiality and integrity.

What information do we collect about you?

AESGP collects personal data about you for a number of reasons, including communicating with you, responding to requests for information, facilitating our events and trainings, and also to administer our membership. We also collect information about the use of our website using cookies (see our Cookie Policy).

In particular, AESGP collects the following categories of personal data:

• Personal identification information (name, email address, phone number, contact details included in an email or in a business card, etc.);
• Publicly available personal data, when it is in our legitimate interests to do this and when these interests do not override your rights;
• Cookies (information your browser sends to us, such as your computer’s IP address, browser version, pages of our website service that you visit, the time and date of your visit, the time spent on those pages);
• Data related to events organised by AESGP (e.g. registration data, photographs, videos, and video recording)
• In some limited cases, other personal information such as age, date of birth, gender, marital status, citizenship, education and employment data (e.g. for our employees or candidates) or financial data (e.g. for our employees and contract partners).

We will never collect sensitive personal data without your explicit consent.

How do we collect your data?

AESGP collects personal data when you:

• work for one of our members and/or you represent that member within AESGP
• communicate with us via email/ hand over your business card to a component of the AESGP secretariat
• work for an entity having a contractual relationship with AESGP
• register to an event organised by AESGP
• send us a resume or respond to one of our job postings 
• publish your personal data on the internet or such data is made public by another party.

To use most of our website, you do not need to provide AESGP with any personal data. However, we do collect non-personal data through cookies. We may collect personal data with your consent when you: 

• send us a query through our contact form
• use public message boards
• sign up to a newsletter
• order a publication

AESGP will never collect sensitive personal data without your explicit consent.

How will we use the information about you?

AESGP collects and processes your data on one of the following lawful bases: consent, contract, legal obligation or legitimate interests. We identify the appropriate ground on a case-by-case basis. 

When AESGP processes personal data of its staff, it does so for the purposes of managing and administering, monitoring and supervising its personnel, based on legal obligations under the Belgian Law on Employment Contracts of 3 July 1978 and/or on the necessity to perform its obligations as employer under the employment contracts signed with its employees or under the consultancy contracts signed with its consultants.

We also process personal data of candidates who apply for job positions at AESGP for the purpose of recruitment activities, based either on the candidates’ consent or on the necessity to conclude a contract with candidates that have been selected. 

AESGP also has a legitimate interest in the processing of personal data to the extent strictly necessary for the purposes of ensuring network and information security. 

AESGP will process personal data for the following purposes: 

• to administer your organisation’s membership, and provide the member’s section of the Website;
• for contract management purposes: e.g. data of representatives and contact persons of entities and associations with which AESGP has contracts in place 
• for public relations and advocacy purposes;
• deliver services, newsletters, literature and/or other materials and information you have requested from us;
• circulate information and/or requests for information regarding legislative and policy developments;
• facilitate conferences and other events organized by AESGP: e.g. based on the necessity for AESGP to meet its obligations as organiser of the events under the general terms and conditions that are expressly accepted by the individuals;
• for payment processing;
• unless you tell us otherwise, we will send you information that we think you may be interested in, including updates on AESGP’s work, policy announcements, upcoming events and training;
• for our own internal administrative purposes and to keep a record of your relationship with us;
• to manage your communication preferences;
• to conduct research, for example, via surveys about your opinion of current services offered by AESGP or of potential new services which may be offered;
• to carry out research to find out more information about our members’ backgrounds and interests; 
• to comply with applicable laws and regulations, and requests from statutory agencies; and
• for websites administration purposes in order to:
• achieve the purpose(s) for which your data was collected (as listed in “How do we collect your data?”)
• answer your requests
• analyse our digital performance (via Google Analytics), for example to see how our Website can be improved to help us better achieve our purposes, and   provide a more optimised and personalised experience. For more information about how we use your personal information in relation to Google Analytics, please view our cookie policy: https://aesgp.eu/aesgp-cookie-policy. 

The legal basis that we rely on for processing your data is either where:

• you have provided your consent to us using your data in a certain way;
• it is necessary so that we can comply with a legal obligation to which we are subject;
• it is necessary so that we can perform our obligations under a contract with you; or
• there is a legitimate interest in us doing so.

“Legitimate interests” means the interests of AESGP in running the organisation and the promotion of our objects, for example, in order to administer membership, run events and administer the organisation. It can also apply to processing that is in your interests, for example in cases where you have requested information or certain goods or services from us.

When we process your personal information for our legitimate interests, we make sure to consider and balance any potential impact on you (both positive and negative), and your rights under data protection laws. We will not use your Personal Data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

Will we share this information with others?

AESGP does not share, sell or rent your information to third parties for marketing purposes. Data collected as part of AESGP general mission may be disclosed with representatives of AESGP members. Beyond the AESGP/members interaction, personal data will not be shared with third parties without your express prior consent. This notwithstanding, we may disclose personal data to service providers supporting the provision of some of our services (website administration, organisation of events, payment processing). When this is the case, third parties only have data on a need-to-know basis for them to complete assignments for AESGP. Third parties are obliged not to disclose or use information for any other purpose.

Data collected from the website will only be used by AESGP to administer the service that you have requested.

Finally, AESGP will disclose your personal information, without notice, only if required to do so by law or in the good faith belief that such action is necessary to: (a) conform to the edicts of the law or comply with legal process served on AESGP or the website; (b) protect and defend the rights or property of AESGP; and, (c) act under exigent circumstances to protect the personal safety of users of the AESGP website, or the public.   

How do we protect the security of personal data?

We aim to ensure that there are appropriate physical, technical and managerial controls in place to protect your personal details.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Our website may contain links to other sites. If you click on a third-party link, you will be directed to that website. As these sites are not operated by us, we strongly advise you to review the privacy notices of these websites, so that you can understand how those sites collect, use and share your information. AESGP is not responsible for the privacy statements or other content on websites outside of the AESGP and AESGP family of websites.

Children’s privacy

Our website services do not address anyone under the age of 13. We do not knowingly collect personal identifiable information from children under 13, and in the case we discover that a child under 13 has provided us with personal information, we will delete this information immediately from our services. Parents or guardians who are aware of their child providing us with personal information should contact us immediately.

Use of Cookies

Cookies are text files placed on your computer to collect standard internet log information and visitor behaviour information. When you visit our websites, we collect information from you automatically through cookies or similar technology. Enabling these cookies is not strictly necessary for the website to work but it will provide you with a better browsing experience. You have the ability to accept or decline cookies. If you choose to decline cookies, you may not be able to fully experience the interactive features of the AESGP websites you visit.

For more information about our cookie policy, please visit: https://aesgp.eu/aesgp-cookie-policy. 

How long do we keep your data for?

AESGP will hold and process your personal data only as long as is strictly necessary to achieve the purpose(s) for which they were collected, or as required to comply with legal obligations.

If you request to receive no further marketing contact from us, we will keep some basic information about you on our suppression list in order to avoid sending you unwanted materials in the future.

What if you have questions or need to make corrections to your information?

You have the right to request details of the information that we hold about you. If you would like to do so, please contact us using the details below.

We also want to make sure that your personal information is accurate and up to date. Please let us know if your details change. We may also use publicly available sources to keep your records up to date (e.g. checking against websites). You may also ask us to correct or remove information you think is inaccurate.

You can also opt-out of receiving all or some of our marketing communications or request that we stop processing data about you for certain purposes, or request that we delete your data at any time by contacting us using the details below.

If you are unhappy with the way in which we have handled your personal data, please contact us using the details below. 

What are your data protection rights?

AESGP would like to make sure you are fully aware of all of your data protection rights. Every data subject is entitled to the following:

• The right to access – You have the right to request AESGP for copies of your personal data. Individuals will not be charged for subject access requests, except if the requests are manifestly unfounded or excessive (e.g. repetitive). In such case, AESGP may charge a reasonable fee.
• The right to rectification – You have the right to request that AESGP correct any information you believe is inaccurate. You also have the right to request AESGP to complete information you believe is incomplete.
• The right to erasure – You have the right to request that AESGP erase your personal data, under certain conditions.
• The right to restrict processing – You have the right to request that AESGP restrict the processing of your personal data, under certain conditions.
• The right to data portability – You have the right to request that AESGP transfer the data that we have collected to another organization, or directly to you, under certain conditions.
• The right to lodge a complaint with a supervisory authority – You have the right to lodge a complaint with a supervisory authority such as the EDPS.

Changes to this Policy

We may update this policy from time to time without notice to you, so please check it regularly. The privacy policy was last updated on 3 February 2021.

How to contact us

If you have any questions about our privacy policy, the data we hold about you, or you would like to exercise one of your data protection rights, please do not hesitate to contact us.

Email: info@aesgp.eu

Post: Avenue de Tervuren 7, 1040 Brussels, Belgium

Phone: +32-2-7355130

AESGP will aim to respond to data subject requests without undue delay and in any event within 6 weeks of receipt of the request.

This Privacy Policy was written with brevity and clarity in mind. Therefore, we are happy to provide any additional information or explanation needed. You may also visit the website https://privacycommission.be to obtain more information concerning the legal framework of privacy in Belgium.