Policy for the processing of personal data pertaining to the client's registrered users in connection with the Federation service SP and IdP

As part of the execution of the agreement between the customer and Belnet, a certain number of processing of personal data must take place. In accordance with the general regulations regarding the processing of personal data, the processing of personal data must be carried out in a transparent and secure manner. 

In addition to the general policy for the processing of personal data of the official persons of the client published on the Belnet Website, this processing policy contains the information, as required by the general regulations, with regard to the processing of data to personal character of the persons mandated for the SP and IdP Federation service.

As the provider of the service, Belnet will fulfil the role of controller of the personal data pertaining to the client's registered users as designated below.

Belnet is a State service with separate management, established within the Federal Science Policy. Its registered offices are located at Boulevard Simon Bolivar 30, 1000 Brussels, Belgium, tel. +32 (0)2 790 33 33, fax +32 (0)2 790 33 34.

The Data Protection Officer at Belnet will be the point of contact for all matters relating to the processing of personal data in general and for this policy for the processing of personal data pertaining to the client's registered users in particular. The Data Protection Officer can be contacted via dpo@belnet.be.

• The specific service purchased by the client
• The Belnet Service Desk and NOC
• Security services (access to infrastructure, such as datacentres)
• Incident handling
• Access to the Belnet portal
• Distribution of surveys commissioned by Belnet
• Mailings from Belnet that relate to the service being provided
• Invitations to events organized by Belnet

The collection and processing of the personal data of registered users on behalf of the client are necessary for the performance of the Agreement.

• Name
• Business e-mail address
• Work telephone number

Belnet will restrict access to personal data by employees, subprocessors or others to the necessary minimum. In accordance with that policy, Belnet will grant access solely to those employees for whom accessing the personal data is a necessity.

To provide the agreed service, Belnet has recourse to third-party service providers. Third-party contractual partners may be granted access to personal data whenever this is necessary for performance of the Agreement but only within the scope of the purposes of processing referred to above.

Belnet undertakes not to retain the personal data collected and processed for any period exceeding that which has been legally and contractually stipulated and agreed on.

The data subject is entitled to submit a request to Belnet to view, modify or delete personal data or to restrict the processing of data pertaining to him or her. The data subject is also entitled to object to processing and enjoys the right of data portability.

Data subjects can exercise the rights referred to above by sending an e-mail to dpo@belnet.be.

In accordance with the procedures laid down under the Regulation, Belnet will comply with such a request within one month. Depending on the complexity and number of requests submitted, this period may be extended a further two months, if necessary.

Whenever a data subject has given consent him- or herself for the processing of his or her personal data for one or more purposes, he or she is entitled to withdraw consent at any time. The withdrawal of consent will not affect the lawfulness of processing based on the consent given before its withdrawal.

If a data subject did not give consent him- or herself for the processing of his or her personal data, the personal data will be deemed to have originated from the client.

To submit a complaint, the data subject can contact the Data Protection Authority at the following address:

Data Protection Authority
Rue de la presse, 35
1000 Bruxelles
E-mail: contact@apd-gba.be

No automated decision-making will occur while the relevant personal data are being processed by Belnet.

Belnet will take appropriate technical and organizational measures when collecting and processing personal data to ensure a level of security appropriate to the risk, in accordance with the principles of the General Data Protection Regulation.

In assessing the appropriate level of security for personal data, which are transmitted, stored or otherwise processed, potential risks posed will be taken into account, such as accidental or unlawful destruction, loss, alteration or unauthorized access.

Belnet reserves the right to amend this policy for the processing of personal data of the persons mandated for the SP and IdP Federation service if necessary and to ensure that such amendments comply with the General Data Protection Regulation.