Who processes your personal data?
4 Peace of Mind (4POM) -a brandname of Delconcy BVBA, is an independent educational institution and advisory firm and provides training by recognised experts with years of experience in the field of data protection, privacy, information security and cloud security. 4POM’s registered office is at Ruitersdreef 10, 2900 Schoten, company number 0885.993.941.
Principles on the processing of personal data
4POM recognises the importance of data protection and privacy of personal data of training participants and will handle the personal data of these data subjects with due care and only for specified purposes. 4POM explicitly confirms that all personal data will be processed in accordance with both the Belgian act of 30 July 2018 on the protection of individuals with regard to the processing of personal data and Regulation 2016/679 of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (hereinafter GDPR).
Which personal data do we process?
Personal data can be defined as any information relating to an identified or identifiable individual (data subject). 4POM may process (both physically and via this website) the following data, which may constitute personal data of the data subject, i.e. personal contact data of the registered person such as:
- First name
- If applicable: contact in the company
- Telephone number
- Evaluations of examinations and obtained scores
- Data on the diet of the registered person for the purpose of providing meals
- Personal data of the person registering, such as surname, first name, title, email
Why do we process this data?
We collect this data to fulfil our administrative obligations such as billing for services provided to the customer by 4POM or keeping our legally required accounts.
For our internal operations, it is also important that we create files to ensure the portability and demonstrability of personal data for purposes of accreditation or certification, for example. This is in the interest of the efficient operation of the company. Specifically, this concerns the following purposes:
- Administrative and organisational tasks related to the registration of the person concerned in one of the 4POM training courses.
- To invite the data subject to events organised by 4POM (for example: the Alumni event).
- Management of the student database.
- Update of course material or training.
- Information on 4POM’s activities.
- Issuing and managing a certificate provided by 4POM, if applicable.
- Direct marketing purposes such as promotions related to the products and services provided by 4POM to the data subject. We use the contact data for activities directly related to 4POM, in particular our products and services offered in the context of lifelong learning (new courses and Alumni activities).
We will only process these personal data for the above purposes unless the data subject’s explicit consent is requested to use them for purposes other than those for which they were originally collected.
To whom do we transfer your personal data?
We do not transfer personal data to third parties such as sponsors or employers, unless explicit permission has been requested from the course participant. 4POM will refrain from releasing personal data to third parties and shall not disclose personal data of data subjects.
Personal data relating to the organisation of the course itself will be transferred to the 4POM-affiliated instructors and parties who support the course day, including the publisher of the course material (only if they deliver personalised course material).
How long do we retain your data?
If the course participant is taking part in a certification programme, the relevant data shall be kept for 15 years after the last contact for the purpose of demonstrating and proving the certification (this refers to administrative data, data on the evaluation, attendance, date of issue of certificate and attendance certificate).
The personal data necessary to justify a subsidy file will be retained for 10 years.
Personal data used for invoicing and accounting purposes are kept for 7 years in accordance with the legal retention period.
For all other purposes, the retention period is 3 calendar years.
What rights can the data subject exercise?
The data subject is able to exercise his/her rights as described in the General Data Protection Regulation at any time. The data subject may exercise the following rights:
- Right of access: the data subject shall always have the possibility to make a request to review all personal data collected (including processing purposes, categories of personal data, estimated retention period). Examination questions are not personal data and are therefore never provided to students.
- Right of rectification or right to restriction of processing: the data subject has the right to demand that 4POM rectifies any of his or her personal data which are inaccurate or incomplete. The data subject may also request that his or her personal data be temporarily withheld until they are accurate or complete.
- Right to erasure (“right to be forgotten”): if the data subject wishes to have his or her personal data deleted, he or she may contact 4POM (firstname.lastname@example.org) at any time, requesting that his or her personal data be deleted. This is a simple and free request. Attention: please note that this right does not always apply, in some cases it is not possible to delete the data, but this will be clearly stated.
- Right to object: if the data subject no longer wishes to be informed of updates or no longer wishes to receive direct marketing emails, he or she has the right to do so. This can be done by emailing a request to email@example.com. Please note that the data subject does not have the right to object to the processing of his or her personal data if such personal data is necessary for the performance of the contract between 4POM and the data subject or the data subject’s company (e.g. for billing the data subject or the data subject’s company for the ordered training, etc.).
- Right to data portability: the data subject has the right to receive his or her personal data in a universally readable format such as a text file or other digital file.
- Complaints: if the data subject is not satisfied with the way his or her personal data are handled, he or she can file a complaint with the competent Data Protection Authority (DPA). For more information, please visit the following website: https://www.dataprotectionauthority.be
Protection of personal data
4POM recognises that the protection of personal data is an essential part of data protection. Where it is impossible to fully guarantee security, 4POM will provide the appropriate technical and organisational measures to protect personal data.