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This Policy is established by :
AISBL APEEE Association des parents d’élèves de l’école européenne de Bruxelles II-Woluwe,
Address: Avenue Oscar Jespers, 75, 1200 Woluwe-Saint-Lambert e-mail: data-protection-office@woluweparents.org
It is registered under the CBE number: 0419.537.272
Hereafter, the “APEEE” or “we“, “our”.
We are particularly attentive to the protection of personal data (hereinafter referred to as “data”) and to the respect of the private life of all persons who come into contact with us.
We act in full transparency, in accordance with related national and international provisions, in particular, 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, and repealing Directive 95/46/EC (General Data Protection Regulation) (Text with EEA relevance) (hereinafter referred to as the “General Data Protection Regulation” or “GDPR”).
This privacy policy describes the measures taken concerning processing your personal data when using our services, including our website https://www.woluweparents.org/ (hereinafter referred to as the Website) and your rights as a user of our services.
It may be modified at any time to comply with any regulatory, legal or technological developments. We invite you to consult it regularly.
You can react to any of the practices described below by contacting us.
The APEEE informs, represents and acts on behalf of all parents of the EEB2 – Woluwe, regardless of whether or not they are members of our association, with the following objectives:
The APEEE is a forum for dialogue and action open to all parents of all language sections. We encourage parents to participate actively in the various decision-making bodies of the school and to promote the “family perspective” in various programmes and educational or community projects in which our children participate. The APEEE is also an important source of support for any family facing difficulties in the system. The APEEE works to ensure the best educational environment for the children of the European School Brussels II.
This declaration is intended for all natural persons whose data we process, such as parents and/or pupils, who use our services or send us an application.
We also process the data of persons who voluntarily provide us with their data, such as prospective parents of pupils.
This declaration is also addressed to all natural persons who act as contact persons for one of our suppliers or for any other company (company, government, employers’ or employees’ professional association, school, university, etc.) with whom we have had, have or wish to have a collaboration. This includes people working for the European School and non-profit organisations that cooperate with us.
Please note that your data will be used in accordance with this privacy policy.
We collect and process your personal data for a number of different reasons based on a legal basis determined by the GDPR (for example, to comply with a legal obligation to which we are subject or to perform a contract with you).
The table below sets out the purposes and legal basis for using your personal data.
| Processing | Purposes | Legal basis |
Management of parents who are members | We process your personal data to carry out operations relating to the management of your membership to our association and to give you access to our activities and services. E.g.: your registration as a member | In accordance with Article 6.1.b) of the GDPR, this processing is necessary to perform contractual or statutory measures. This processing is necessary for the fulfilment of our legal obligations in |
| accordance with Article 6.1.c) of the GDPR. | ||
| Management of our services and activities | We process personal data to provide our services in accordance with our statutes. E.g. transport services, canteen, extracurricular activities and daycare. Regarding pupils ‘data, this enables the updating classes and the proper provision of our services in full security. We process personal data in the context of support projects responding to a call for projects. E.g. implementation of welfare or art projects; group purchase of various materials such as calculators, sports uniforms; book exchange. | This processing is necessary for the performance of our obligations to you, in accordance with Article 6.1.b) of the GDPR. This processing is necessary to fulfil our legal obligations in accordance with Article 6.1.c) of the GDPR. |
| Management of parent delegates and representation (working groups, task forces, etc.) | We process personal data in order to represent parents and act on their behalf in various working groups, task forces, committees or other organisational structures | This processing is necessary for the performance of our obligations to you in accordance with Article 6.1.b) of the GDPR. This processing is also necessary for the performance of our legal obligations in accordance with Article 6.1.c) of the GDPR. |
| Managing elections and our bodies | We process your personal data to ensure the management of our AISBL, to organise our Boards of Directors and General Meetings, as well as the elections of our bodies, including the sharing of data with the Moniteur Belge, or the UBO register for official publications. | This processing is necessary for the performance of our legal obligations in accordance with Article 6.1.c) of the GDPR. |
| Managing our communication | We process personal data in order to provide you with information about our services. We may use your data to fulfil our legitimate interests or those of third parties, without prejudice to your interests or fundamental rights and freedoms, to offer and promote all services and/or to share with you informative messages that | We may process your data, in accordance with the provisions of Article 6(2)(f), on the basis of our legitimate interest, provided that we have weighed this interest against your interests or fundamental rights and freedoms by considering your “reasonable expectations”. |
| are consistent with what you may reasonably expect from us in the context of our existing or possible future relationship. | You may object to this processing by contacting us. | |
| Pre-contractual relationship management | We process your personal data in order to respond to requests and/or questions you send us (in particular via the contact form on our site), or if you send us your CV to apply for a job with us. | In accordance with Article 6.1.b) of the GDPR, this processing is necessary for pre-contractual measures. |
| Management of our litigation | We may use your data to meet our legitimate interests or those of third parties in defending our interests (or those of third parties) in court in the context of our existing or possible future relationship. | We also have a legitimate interest in processing personal data in order to defend our interests, in particular but not exclusively in the context of a dispute or legal action based on Article 6.1.f) of the GDPR. We may also need to process sensitive data in this context, in accordance with the provisions of Article 9 §2, f) of the GDPR. |
| Management of our suppliers | We process personal data in order to fulfil our contractual obligations to you or your company. Data from service providers related to the business may also be published on our website only with your consent in order to ensure communication. | Fulfilment of our commitments to you in accordance with Article 6.1.b) GDPR. This processing is necessary for the performance of our legal obligations in accordance with Article 6.1.c) of the GDPR. You have given your consent to the processing of your data in accordance with Article 6.1.a) of the GDPR. |
Unless there is a legal exception, you may object to processing that is based on our legitimate interest, or on your consent, at any time by contacting us.
We only collect personal data that is adequate, relevant and limited to what is strictly necessary for the purposes for which it is processed.
Depending on the purpose, data is collected differently.
Below we detail the personal data we collect about you, as well as the way in which we collect it.
| Procesing | Data collected and processed | Collection method | |
| Management parents who are members. | of | Personal identification data (surname, first name, address, telephone number, etc.) Electronic identification data (e-mail address, encrypted password, etc.) Professional characteristics (profession, etc) Family data (first and last names of children, parental authority, class of children) Financial data (account number). Photographs | Directly from you We have received it by the European school |
Management our services activities | of and | Personal identification data (surname, first name, address, telephone number, order number, etc.) Electronic identification data (IP address, e-mail address, encrypted password, etc.) Personal family characteristics (marital status, custody of children) Financial data (account number). Student’s personal identification data (surname, first name, address, telephone number, school identification number) Student’s family data (siblings, …) Personal characteristics of the student (age, sex, date of birth, country, language) Health data of some students where parents feel it is necessary for some of our activities. Pedagogical data (language skills, site, cycle, section, class level, grade…) Photographs | Directly from you, especially from our website (online registration) We have received it by the European school |
Management of parent delegates and representation (working groups, task forces, etc.) | Personal identification data (surname, first name, address, telephone number, etc.) Electronic identification data (e-mail address, encrypted password, if any, etc.) Family data, (first and last names of children, year of schooling of children) Photographs (if any) | Directly from you | |
| Managing elections and our bodies | Personal identification data (surname, first name, address, telephone number, etc.) Electronic identification data (IP address, e-mail address, encrypted password, etc.) Personal characteristics (age, gender, date of birth, your country, language, EU ID) Photographs Copy of identity card Status of parent representative. | Directly from you | |
Managing our communication | Personal identification data (surname, first name, address) Electronic identification data (IP address, e-mail address) Family data, (first and last names of children, children’s school year, language section) | Directly from you We have received it from the European school | |
| Pre-contractual relationship management | Personal identification data (surname, first name, address, telephone number, order number, etc.) Electronic identification data (IP address, e-mail address, etc.) Family data (first and last names of children, marital status) Personal characteristics (age, gender, date of birth, your country, language) Professional characteristics (profession, degree, career, etc.) | Directly from you You have made them publicly available From the European School. | |
Management of our litigation | Personal identification data (surname, first name, address, telephone number, order number, etc.) Electronic identification data (IP address, e-mail address, encrypted password, etc.) Personal characteristics (age, gender, date of birth, your country, your language) Financial data (account number, outstanding debts, etc.) only if you subscribe to a paid service. Health data and any data necessary to defend our interests in court. Photographs. | Directly from you You have made them publicly available | |
Management our suppliers | of | Personal identification data (surname, first name, address, telephone number, order number, etc.) Electronic identification data (IP address, e-mail address, etc.) Financial data (account number, open claims, etc.). | Directly from you You have made them publicly available |
The data listed above is accessible to members of our team, or collaborators, if any, to our lawyers or any technical advisors, to banking or insurance organisations to the extent strictly necessary.
Your data will also be transferred between the European School and our services on the basis of your consent.
We may also transfer your data :
We may also provide access to certain data to our co-contractors, qualified as “subcontractors” within the meaning of the GDPR, to the extent strictly necessary to achieve our purposes, such as the operation of computerised or non-computerised applications or management systems.
In all circumstances, we ensure the protection of your data through confidentiality agreements.
The service providers with whom we share your data are the following:
| Category of service provider | Location | |||
| Email solution providers | In Europe | |||
| Mailing providers | In Europe | |||
| IT solutions providers and maintenance | infrastructure | and | systems | In Europe |
| Social networks | In Europe | |||
| Hosting/cloud service providers | In Europe | |||
| Lawyer and legal service providers | In Europe | |||
| Social secretariat | In Europe | |||
| Accountant and financial service provider | In Europe | |||
| Communication tools | In Europe and the United States | |||
| Other organisation | In Europe | |||
| Banks | In Europe | |||
For security reasons, the list of subcontractors, their field of activity, the purpose for which the data is processed and, if applicable, the country in which the data is processed and hosted, is not available on our website, but on first request by the data subjects.
We make transfers to the United States. Such transfers will only be permitted if and when :
The absence of an adequacy decision or appropriate safeguards, a transfer or a set of transfers of personal data to a third country remains possible if such transfer is necessary for the establishment, exercise or defence of legal claims.
The period of retention varies according to the purposes for which your data is processed. This period is limited taking into account any retention obligations imposed on us by law. You will find the list of purposes and the retention periods below.
| Processing | Retention period | |
| Management of parents who are members. | The retention period is 2 years from the end of your membership in our association. | |
| Management of our services and activities | The retention period is 7 years from the end of the membership of the APEEE or the cessation of the activity or | |
| service in question in order to respond to the Commission’s request in the context of the financing of the activities. | ||
| Management of parent delegates and representation (working groups, task forces, etc.) | The data will be kept for 2 years from the end of your mission as a class representative or member of a working group | |
| Managing elections and our bodies | The period of retention of the data is 5 years from the closure of the liquidation of our AISBL. (Art. 2:143, 3:103, and 9:3 of the Companies and Associations Code) | |
| Managing our communication | The retention period is 5 years from the last use for legitimate communication purposes | |
| Pre-contractual management | relationship | The retention period is 3 years from our last contact |
| Management of our litigation | The data are deleted after the execution of the judgment or the final closure of the dispute. | |
| Managing our suppliers | The data is kept for 7 years from the last day of the year in which your data is entered into our accounting system (Art. III.86 and III.88 of the Economic Law Code and Art. 8 of the Royal Decree implementing Articles III.82 to III.95 of the Economic Law Code) | |
In order to ensure the highest level of security for the data collected on the website, we implement appropriate technical and organisational measures (encryption technology and security measures to protect and prevent the loss, misuse or alteration of the information collected on the websites). We take into account the state of the art, the costs of implementation and the nature, scope, context and purposes of the processing as well as the risks to your rights and freedoms.
In all circumstances, we ensure an adequate level of technical and organisational security of your data, in order to protect you from data leakage, including loss, destruction, public disclosure, unauthorised access or misuse. However, if you are aware of or suspect a data breach, we ask that you report it immediately by contacting us.
For security reasons, the list of subcontractors, their field of activity, the purpose for which they process data and, if applicable, the country in which the data is processed and hosted, is not available on our website, but on first request by the persons concerned. The same applies to the list of security measures.
Except where not permitted by a legal provision in force in Belgium, including the GDPR, under the regulations you have the following rights:
Rue de la Presse, 35, 1000 Brussels
Tel: +32 (0)2 274 48 00
Fax: +32 (0)2 274 48 35
E-mail: contact@apd-gba.be
You can also file a complaint with the court of first instance.
For more information on complaints and possible remedies, you are invited to consult the following address of the Data Protection Authority:
https://www.autoriteprotectiondonnees.be/citoyen/agir/introduire–une–plainte
If you need more information about your rights, please contact us. We will respond to your request as soon as possible and, at the latest within one month of receiving your request, we will inform you of the action we have taken.
Depending on the difficulty of your request or the number of requests we receive from other people, this deadline may be extended by two months. In this case, we will notify you of this extension within one month of receiving your form.
In all circumstances, when providing this information, we are always obliged to take into account the rights and freedoms of other persons.
If you wish to react to any of the practices described in this Policy, or if you wish to exercise your rights, you may contact us by e-mail at the following address: data-protectionofficer@woluweparents.org
or by post to the following address :
AISBL APEEE Association des parents d’élèves de l’école européenne de Bruxelles II-Woluwe,
Address: Avenue Oscar Jespers, 75, 1200 Woluwe-Saint-Lambert.
We ask the persons concerned to attach to their application the documents or information necessary to prove their identity, failing which we may return to them to request proof of their identity, for example a copy of their identity card, with a view to taking appropriate action on their application.
Finally, when the request to exercise a right is manifestly unfounded or excessive, in particular because of its repetitive nature, it may be refused or be subject to the payment of reasonable fees that take into account the administrative costs incurred in providing the information, making the communications or taking the measures requested.
10. We use cookies on our websites.
A cookie is a piece of code in the form of a file stored on your computer. Cookies help us to improve our site, make it easier for you to navigate and analyse our audience.
To learn more about our policy on cookies and other tracking devices, please visit our website under the “Cookies Policy” tab.
11. What is the applicable law and jurisdiction?
This Policy is governed by Belgian law.
Any dispute relating to the interpretation or execution of this Policy shall be subject to Belgian law.
This Policy may be updated at any time without notice. We advise you to consult it regularly. The most current version can be consulted at any time on our website.
Last updated on 26 April 2021.
Avenue Oscar Jespers 75, 1200 Woluwe St Lambert
Avenue du Bourget 30, 1140 Evere
Updated on 19/01/2024 – 11:50