European Trade Union Committee for Education

ETUCE needs to gather and use certain information about individuals. These can include member organisations, suppliers, business contacts, visitors, employees and other people the organisation has a relationship with or may need to contact.

Safeguarding the personal data of all these persons is an essential aspect of protecting people’s lives, integrity and dignity. The processing of personal data touches upon all areas of ETUCE’s activity, whether operational or administrative.

The European Trade Union Committee for Education (ETUCE) is the European Region of Education International (EI), the global federation of education unions.

ETUCE's activities, websites, events and communications form part of the activities of Education International. ETUCE and EI use integrated information and communications systems, including common systems for contact management, event management, communications, collaboration and other organisational purposes.

Education International (EI) is the data controller for personal data processed through these systems, including personal data collected in connection with ETUCE's activities. ETUCE processes personal data within this organisational framework and in accordance with EI's data protection policies and procedures.

This policy explains how personal data is collected and used in connection with ETUCE's activities. It should be read together with Education International Data Protection Policy. Where this policy does not specifically address a matter, EI's Data Protection Policy applies. EI's policy expressly applies to websites, software and services owned, operated or used by EI and its subsidiaries.

Education International and ETUCE are committed to complying with the EU General Data Protection Regulation (GDPR) and other applicable data protection legislation.

1. Personal data we collect 

In connection with ETUCE's activities, EI may collect and process personal data relating to, among others:

• representatives and staff of member organisations;

• members of the ETUCE Committee, standing committees, working groups and networks;

• participants in conferences, seminars, meetings, webinars and other events;

• subscribers to ETUCE communications;

• project participants and partners;

• suppliers and service providers;

• applicants, consultants and staff; and

• visitors to ETUCE websites and users of EI and ETUCE digital services.

Depending on the activity, this information may include:

• name and contact information;

• organisation, position and professional information;

• mailing address and telephone number;

• communication and subscription preferences;

• information submitted through forms or correspondence;

• event registration and participation information;

• travel or accommodation information where required for events;

• information necessary for administering committees, projects or networks;

• technical information such as IP addresses and information generated when using websites or online services; and

• other information voluntarily provided in connection with an ETUCE or EI activity.

Personal data collected through EI and ETUCE websites and platforms may be stored within EI's integrated information systems, including EI's central Customer Relationship Management system (CRM). This reflects EI's existing policy that data submitted through its websites or platforms may be stored in its CRM.

2. How we use personal data 

Personal data may be processed for purposes including:

• administering ETUCE membership and relations with EI member organisations in Europe;

• operating the ETUCE Committee, standing committees, working groups and networks;

• organising conferences, meetings, webinars, seminars and other events;

• administering EU-funded and other projects;

• providing information requested by individuals or organisations;

• sending circulars, newsletters, campaign information and other relevant communications;

• conducting consultations, surveys and policy work;

• maintaining contact information and organisational records;

• administering accounts and access to EI or ETUCE digital platforms;

• complying with contractual, financial, reporting and other legal obligations;

• maintaining the security and effective operation of EI and ETUCE information systems; and

• supporting EI's and ETUCE's legitimate organisational and trade union activities.

Depending on the circumstances, processing is based on consent, contractual necessity, compliance with a legal obligation, or the legitimate interests of Education International in carrying out its statutory and organisational activities.

Where consent is the legal basis for processing, it may be withdrawn at any time, without affecting the lawfulness of processing carried out before withdrawal.

Certain communications are necessary for the functioning of ETUCE bodies, projects or the relationship between Education International and its member organisations. It may therefore not always be possible to opt out of such operational communications.

3. Communications and newsletters 

Individuals may subscribe to ETUCE newsletters, circulars or other optional communications and can unsubscribe from these communications using the unsubscribe facility provided or by contacting us.

Communications that are necessary for participation in an ETUCE committee, working group, network, project or event, or that are necessary in connection with membership of Education International, are considered operational rather than optional marketing communications.

Where newsletter or email tracking technologies are used, they are governed by the Education International Data Protection Policy. EI's current policy distinguishes consent to receive a newsletter from consent to newsletter tracking and provides for separate consent to optional tracking.

4. Sharing personal data and service providers 

Personal data processed in connection with ETUCE activities may be accessible to authorised staff of ETUCE and Education International where access is required for their work.

Because ETUCE is the European Region of Education International and uses EI's integrated information systems, the movement of information between ETUCE and other authorised parts of EI does not constitute the transfer of data to an unrelated organisation. Access remains subject to organisational access controls and the purposes for which the information was collected.

Education International also uses contracted service providers to operate its information systems and deliver services. EI's current Data Protection Policy identifies services including Microsoft, Cvent, Bynder, ClickDimensions and Google Analytics, among others. Such providers may process personal data on EI's behalf and are authorised to use it only as necessary to provide the contracted service.

Personal data may also be disclosed where required by law, or where necessary to protect EI's rights, protect individuals, investigate fraud or comply with judicial proceedings or lawful requests from public authorities.

Education International does not sell personal data.

5. Data security 

Education International takes appropriate technical and organisational measures to protect personal data against unauthorised access, unlawful processing, accidental loss, destruction or damage.

ETUCE benefits from the integrated security arrangements covering EI's information infrastructure, including access controls, encryption and other organisational and technical security measures.

EI's Data Protection Policy provides further information on the technical and organisational measures used to protect its information systems.

6. Retention of personal data 

Personal data is retained only for as long as reasonably necessary for the purpose for which it was collected, or for a longer period where required by applicable law, contractual obligations, financial or audit requirements, organisational record-keeping requirements, or other legitimate purposes.

Retention periods therefore depend on the type of information and the purpose for which it is processed.

Specific retention periods set out in the Education International Data Protection Policy apply where relevant.

7. Cookies and website analytics 

ETUCE websites may use cookies and similar technologies that are necessary for operation of the websites or used for functionality, analytics or other permitted purposes.

Where required by applicable law, non-essential cookies and tracking technologies will be used only following the user's consent.

Users can manage their choices through the cookie controls provided on the relevant website and may also configure their browser to restrict cookies.

Further information concerning cookies, analytics and tracking technologies is available in the Education International Data Protection Policy.

8. International data transfers 

Education International is an international organisation and uses systems and service providers that may involve processing or transferring personal data outside the European Economic Area.

Where personal data is transferred internationally, EI applies appropriate safeguards in accordance with applicable data protection legislation.

Further information on international data transfers is provided in the Education International Data Protection Policy.

9. Your data protection rights 

Subject to the conditions established by applicable law, individuals have rights concerning their personal data, including the right to:

• obtain information about how their data is processed;

• request access to their personal data;

• request correction of inaccurate or incomplete information;

• request deletion of personal data;

• request restriction of processing;

• object to certain processing;

• withdraw consent where processing is based on consent; and

• exercise applicable data portability rights.

Individuals also have the right to lodge a complaint with the competent supervisory authority.

Requests concerning personal data processed in connection with ETUCE activities can be submitted through ETUCE or directly to Education International's Data Protection Officer.

10. Data breaches 

Suspected or confirmed personal data breaches involving ETUCE activities or systems must be handled within Education International's data protection and incident-management framework.

Where required under the GDPR, Education International, as data controller, will notify the competent supervisory authority without undue delay and, where applicable, within 72 hours after becoming aware of a personal data breach. Where the breach is likely to result in a high risk to individuals' rights and freedoms, affected individuals will also be informed as required by law. EI's current policy identifies the Belgian Data Protection Authority in this context.

11. Data controller and contact details 

The data controller is:

Education International (EI)

Attn: Data Protection Officer

15 Boulevard Bischoffsheim

B-1000 Brussels  Belgium

Telephone: +32 2 224 06 11

Questions or requests relating specifically to ETUCE activities may also be submitted through ETUCE at privacy@csee-etuce.org. ETUCE will coordinate such requests with Education International as data controller where necessary.

The Education International Data Protection Policy provides EI's full Data Protection Officer contact details and procedures for requesting access, correction or deletion of personal information.

12. Relationship with the EI Data Protection Policy 

This ETUCE policy supplements the Education International Data Protection Policy by explaining how that policy applies specifically to ETUCE as the European Region of Education International.

In the event of an inconsistency between this policy and the Education International Data Protection Policy, the EI policy and applicable data protection legislation prevail.

ETUCE and Education International may update this policy from time to time to reflect changes in their activities, information systems, legal requirements or data protection practices.