Article 1 – General
Belgatech has undertaken to bring its data processing activities in compliance with applicable data protection laws, including the EU Regulation 2016/679 of 27 April 2016 on the protection of personal data (the “GDPR”).
Article 2 – Personal data that we process about you
We process the following personal data about you:
2.1. During a visit to our website:
- IP address;
- Profile name, password, e-mail address, login data (and possibly profile picture) when registering on our website;
2.2. When subscribing to our newsletter:
- E-mail address;
2.3. In the context of your employment with us:
- Name, address, e-mail address, telephone number;
- Photos and videos;
- CV, motivation letters, notes made during the job interview;
- Information on education and work experience;
- Evaluation forms and results of any tests and assessments;
- Payroll information including national register number, address, seniority, civil status, bank account number, gender, family composition, date of birth;
- Information about your remuneration, including, where applicable, salary sheets, fiscal slips, pay periods, overtime, benefits, leave entitlements, sickness and absences, trade union membership;
- Information about your personal preferences;
- Information related to your job including, where applicable, job title and description, job location, identification number, professional address, telephone numbers and email addresses, start and end-dates of work, work status, contract type;
- Travel and accommodation information including travel itineraries, travel preferences, frequent travel program numbers and travel reward cards;
- Purchase history through your use of corporate credit cards ;
- Phone subscription information (ingoing and outgoing phone numbers, time and duration of calls, countries of incoming and outgoing calls);
2.4. As representative of our customers, suppliers, as a customer (e.g. where we provide demarcation studies) or as some other business relation:
- Name, address, e-mail address, telephone number, job title, bank account number, VAT details;
2.5. As a job candidate:
- Name, address, e-mail address, telephone number;
- CV, motivation letters, notes made during the job interview;
- Information on education and work experience;
We may ask you to complete standardised tests for us to assess you work aptitudes;
2.6. As visitor or an employee on our premises:
- Name, date, time in and time out, if you register yourself at the front desk;
- CCTV footage;
2.7. As an employee on our premises for you to access our premises:
- Identification data;
- Access times (dates and hours of entry to the premises);
Please note that such data are processed through individually issued badges;
- CCTV footage.
For compliance with applicable immigration requirements and to facilitate corporate travel, we may also process your copies of your passport or other identity documentation, citizenship, immigration status, residency and working visas to the extent permitted by applicable law.
For administering benefits (including health benefits and leave entitlements) and managing maternity programmes, we may process certain health-related information such as disability condition, information related to leave entitlements, sicknesses and absences and maternity leave information to the extent permitted by applicable law. We may also process copies of your health certificates in the context of following-up on work-related accidents or sickness and absences.
For managing our company fleet and/or when your job requires it, we may process copies of your driver’s license or driving record, the licensing plate of the vehicle you are using and any parking tickets.
To the extent permitted by applicable law and for the purpose of operating, administering and safeguarding our IT systems, we process electronic identification and communication data (e.g. call history, caller identifier and log-in credentials to access professional accounts).
Article 3 – Source of the data
We collect your personal data directly from you.
However, we may process publicly available personal data, e.g. data that are subject to a publication duty, such as the publication of your appointment as director of a company, data that you made public yourself, such as information posted on your website or on publicly accessible social media accounts or data that are generally known in your region or that have appeared in the press.
Article 4 – Purposes of the processing
4.1. General purposes:
Belgatech will process your personal data exclusively for the following purposes:
- IP address (see article 2.1): for improving our website, with as legal basis the pursuit of our legitimate interests in continuously improving our website;
- Profile name, password, e-mail address, login data (and possibly profile picture) (see article 2.1), when registering on our website to manage your account on our website and to provide you with the requested information or services, with as legal basis the execution of an agreement that was requested by you;
- E-mail address (when registering for the newsletter)(see article 2.2.): to send you direct marketing communications, newsletters, employment information or information on planned activities (lectures, seminars, working lunches), with as legal basis your prior consent;
address, e-mail address, telephone number, CV, motivation letters,
notes made during the job interview, information on education and
work experience, evaluation forms and results of any tests and
assessments, payroll information, information about your
remuneration, information about your personal preferences,
information related to your job, travel and accommodation
information, your purchase
history through your use of corporate credit cards, your phone
subscription information (see
- to perform our obligations under your employment contract or under any contract related to the work you do, such as paying your remuneration, managing disciplinary measures, organising secondments or managing your work assignments, with as legal basis the execution of an agreement;
- to comply with a legal obligation applicable to us, such as obligations pursuant to applicable accounting, fiscal, labour and social security laws;
- the pursuit of our legitimate interests, such as organising teambuilding activities, promoting our activities or training and evaluating our staff;
- Photos and videos (see article 2.3): to be used for our internal communication, with as legal basis the pursuit of our legitimate interests to allow our staff to connect to each other. We may also take pictures of you as part of our teambuilding and social activities or as part of our corporate events and publish them on our intranet, website and/or social media accounts or send them through our internal newsletters. We may also include photos of you in our requests of proposals or commercial propositions to (prospective) clients. We may also use photos of you in the context of client testimonials, in which case we will ask you for your prior authorisation;
address, e-mail address, telephone number, job title, bank account
number, VAT details (see
- to provide you with the requested services, with as legal basis the execution of a services agreement or the performance of necessary pre-contractual steps;
- to send you direct marketing communications, with as legal basis your prior consent or, if consent is not required, our legitimate interests to contact you for commercial or marketing purposes;
- Name, address, e-mail address, telephone number, CV, motivation letters, notes made during the job interview, information on education and work experience (see article 2.5): for our recruitment purposes, with as legal basis the performance of necessary pre-contractual steps for entering into an employment contract (or other work-related contract) with Belgatech;
- Name, date, time in and time out, access times (see articles 2.6 and 2.7): if you register yourself at the front desk or if you access our premises through your individually issued badge, to perform access controls to our premises for the pursuit of our legitimate interests to ensure the safety and the security of our premises;
- CCTV footage (see articles 2.6 and 2.7): if you are entering our premises. The processing of your images is necessary for the pursuit of our legitimate interest to gather evidence of incivilities and of acts constituting offences or causing damage and to search for and identify the perpetrators of those acts, persons who are disturbing the public order, witnesses and victims.
For the use and maintenance of our internal or external communications networks, equipment, applications or devices (e.g. through voicemails, conference calls, e-mails, correspondence, documents and other work products and communications), we process personal data contained or revealed through the use or maintenance of such communications means, only to the extent permitted by applicable law.
More generally, we may also process your personal data:
- To carry out corporate restructuring operations;
- For internal and external audits;
- For the management of disputes with customers, suppliers, employees and other data subjects.
4.2. Direct marketing:
If you are a representative of our customers or suppliers or some other business relation, we are processing your personal data for direct marketing purposes. We will only contact you by email (or other form of electronic communication) for direct marketing purposes if we have obtained your prior consent and if so required by applicable law.
You may withdraw your consent or object to the processing of your personal data for direct marketing purposes at any time, free of charge and without any obligation to give a justification by contacting our Data Protection Correspondent via email at firstname.lastname@example.org or by post at Belgatech Engineering Services SPRL, Boulevard de la Woluwelaan 2, 1150 Brussels.
The possible consequences of not providing your personal data could include our inability to meet our obligations under a contract (e.g. paying your remuneration as part of an employment contract) or a breach by us of one or more obligations under applicable laws (e.g. accounting, tax, labour or social security laws).
4.4. Transfer to data recipients:
Where relevant, Belgatech may transfer your personal data to the following categories of recipients:
you are an employee, trainee, intern and/or other type of worker:
- The members of the Human Resources department of Belgatech;
- Belgatech’s customers in the context of the preparation of missions (including staff secondments);
- Payroll service providers;
- Benefits administrators;
- Financial consultants and financial services providers (including credit card companies);
- Employee-specific IT and software solutions providers;
- Telephone providers;
- Corporate insurers;
- Car management/leasing companies;
you are a representative of our customers or suppliers, a customer
or some other business relation:
- Relevant business managers or account managers;
- Technical service providers who handle technical support to the extent necessary for the provision of services.
Belgatech may generally disclose your personal data to the following categories of recipients in the context of its activities:
- The members of the IT department of Belgatech;
- The members of the Legal department;
- The affiliated entities of Belgatech;
- IT systems providers and consultants (including enterprise resource planning and cloud-based software providers and consultants);
- Outside legal counsel;
- Government entities authorised to access and/or obtain your personal data in accordance with applicable law;
- The courts and tribunals of the judicial order in the event of a dispute involving you;
- Law enforcement authorities in the event of a finding or a suspicion of the occurrence of an offence involving you in accordance with or as required by applicable law.
Belgatech will not sell your personal data, rent them out, share them or otherwise make them commercially available to third parties, except as described above or unless with your prior consent.
Article 5 – Duration of the processing
We ensure that your personal data are kept for no longer than is necessary for the purposes for which they are processed as described in article 4.
We use the following criteria to determine the retention periods of personal data according to the context and purposes of each processing operation:
- The date of the end of your commercial relationship with Belgatech;
- The date of the end of your employment, traineeship, internship and/or work with Belgatech;
- The sensitivity of your personal data;
- Security reasons (for example, the security of our premises or of our information systems);
- Any current or potential dispute or litigation involving you;
- Any legal or regulatory obligation to retain or delete personal data (for example, a retention obligation imposed by accounting, tax, labour laws or social security laws).
Article 6 – Your rights
6.1. Right of access:
You have the right to access your personal data and to obtain information about the use by Belgatech of your personal data.
6.2. Rights to rectification, erasure and restriction:
You have the right to ask us to rectify your personal data when they are incomplete or inaccurate. You have the right to request us to erase your personal data. However, the right to erasure is not absolute and is subject to special conditions. We may retain your personal data to the extent permitted by applicable law, and in particular when their processing remains necessary to comply with a legal obligation to which we are subject or for the establishment, exercise or defence of a legal claim. You acknowledge that certain services and products may not be provided as a result of the exercise of your right to erasure.
You also have the right to ask us to restrict the processing of your personal data under certain conditions.
6.3. Right to object:
You have the right to object to certain types of processing (e.g. when the processing is based on our legitimate interests and, taking into account your particular situation, your interests or fundamental rights and freedoms prevail).
In addition, you always have the right to object to the processing of your personal data for purposes of direct marketing; in such a case, you do not have to give any reasons.
6.4. Right to data portability:
Subject to certain conditions, you have the right to obtain the personal data that concerns you and that you have provided in a commonly used and machine-readable format and/or to transmit them to other data controllers.
6.5. Right to withdraw consent:
If the processing of your personal data is based on your consent, you have the right to withdraw this consent at any time.
6.6. Exercising your rights:
You may exercise your rights by contacting our Data Protection Correspondent via email at email@example.com or by post at Belgatech Engineering Services SPRL, Boulevard de la Woluwelaan 2, 1150 Brussels. We will try to comply with your request as soon as reasonably practicable and always under the timeframes set forth by applicable data protection law. Please note that, if we have doubts about your identity, we may require you to provide us a proof of your identity to prevent unauthorised access to your personal data.
6.7. Automatic decisions and profiling:
The processing of your personal data does not include any profiling, nor will you be subject by us to automated decisions.
6.8. Right to lodge a complaint:
You have the right to lodge a complaint with the competent supervisory authority. For Belgium, this is:
Data Protection Authority
Rue de la presse / Drukpersstraat 35
Tel +32 (0)2 274 48 00
Fax +32 (0)2 274 48 35
This leaves intact the possibility of seeking relief before a civil court.
If you should suffer harm as a result of the processing of your personal data, you can file a claim for damages.
Article 7 – Security and confidentiality
We have developed security measures that are appropriate on the technical and organisational levels to prevent the destruction, loss, falsification, modification, unauthorised access by or unauthorised disclosure to third parties of collected personal data as well as any other unauthorised processing of these data.
If you have received login and access codes from Belgatech, you must at all times observe the security rules, including by preventing any unauthorised access to your login and access codes. You are responsible for the unauthorised use that is made of your login and access as well as for the confidentiality thereof.
Article 8 – Miscellaneous
If you have any questions about the way Belgatech processes your personal data, please contact our Data Protection Correspondent via email at firstname.lastname@example.org.