FARNET
Fisheries Areas Network

FARNET Privacy Policy

FARNET Support Unit Privacy Policy:
Our Privacy Statement on the protection of personal data

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This document describes the privacy policy of the FARNET Support Unit (FSU). It affects all data gathered and processed through the FARNET website or during events and communication actions by the FARNET Support Unit. 
This policy is a derivative of the GDPR, and it is to be applied to FARNET activities; FSU data processing; and, data and information systems.

1 The General Data Protection Regulation (GDPR)

Data processing and the FARNET website are managed by the FSU for the Directorate General Maritime Affairs and Fisheries, Directorate D – Fisheries Policy, Mediterranean and Black Sea, Unit D/3 – CFP and Structural Support, Policy Development and Coordination.
The GDPR is EU 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. It repeals Directive 95/46/EC. The GDPR came into force on 25 May 2018. More information can be found on the EC GDPR site.

2 FSU as data owner and processor

For some FSU services and activities, the FSU gathers personal data through the means identified below (section 3). FSU is the owner and processor of this data, treats it with confidentiality, and does not pass it onto third parties. 
All data gathered and processed by the FSU is subject to the EU General Data Protection Regulation (GDPR), which aims to protect the privacy of all EU inhabitants. Note that the FSU makes use of the IT services of European Commission to host and support the FARNET website. 
The FARNET Support Unit is managed by the DEVNET EEIG, both located at the same address (see section 8-“Website operator and data controller” at end of the page).

3 Services requiring personal data

For some of the services and activities of the FSU, an account and/or processing of personal data is necessary. We are collecting your data on an opt-in/opt-out basis. Data collected remains in our database for information purposes. By entering your personal data and/or creating an account you agree to the data processing.
The following is a list of the FSU activities and systems which make use of personal data. This data is kept for as long as the corresponding programming period of the European Commission lasts, and at least as long as it is required for legal purposes (see section 5‑“How long do we keep your data?” below).
 
3.1 Personalisation of access to the system (i.e. registration on the FARNET website) and provision of information
Access to the FARNET website and online communities is based on the EU Login system. A user willing to access function-based services like the myFARNET communities on a personal usage needs to create a user account on the FARNET website by using the EU Login system . Personal data collected includes email address, password, chosen fields of interest.
 
3.2 The Contact Us form
The feedback is temporarily stored in the functional mailboxes where the questions or feedback are sent, and contains the (full) name, email address and type of organisation. Other, non-requested / voluntary information can contain (depending on your own email system): office address, phone, fax, organisation or institution to which the requester belongs. After the feedback is processed, the information is either deleted or stored for the related follow-up process, depending on the nature of the request (e.g. in the case of contract/administrative matters, the content and related information may be stored for the duration of the programming period, plus the possible auditing legal duration).
 
3.3 Mailing lists and Newsletter registration
The FSU informs you about the European Fisheries Areas Network’s activity through the FARNET Flash newsletter. You may receive alerts on updates on our website or be contacted in the framework of surveys and invitations to FARNET events.
The FSU manages mailing lists which were created to send out FARNET newsletters, to facilitate events, to allow for working-group communication, etc. Each email sent via these mailing lists contains an unsubscribe link and a contact address. 
For communications, the FSU can use the services of MailChimp for this purpose. MailChimp functions in this instance are used as the data processor – you can find the MailChimp privacy policy  here in addition to the related GDPR and privacy policy of the corresponding mailing lists.
Two key mailing lists are set up in the MailChimp environment for FARNET activities - the Newsletter mailing list and the FARNET activities mailing list (events, surveys, notification of key background information related to FARNET context, etc.). 
  • Any registered user to the Newsletter mailing list can unsubscribe at any time from that list by using the unsubscribe link present in a Newsletter mailing campaign.
  • Users registered to the FARNET mailing list can request to unsubscribe from that mailing list. That request will be assessed and the mailing list will be corrected in the following way:
    • Users without any contractual or administrative link with FARNET or the DG MARE context will be removed from the mailing list.
    • Users involved in a proxy-contractual relationship (like a project promoter involved in programme testimony, for example in relation to a funding or supported event) have the right to review stored personal information. If their personal information can be replaced by information related to the contracted organisation, then their data can be removed from the mailing list. If some data cannot be replaced by other official representative data, then the personal data will be removed as much as possible from the database, and the corresponding email address excluded from as many of the usual mailing campaigns as possible.
    • Users involved in a tighter contractual or official role (like representative of Managing Authorities, Intermediate Bodies, National Networks, Legal contact of a FLAG, FSU representatives, etc.) may be kept in the mailing list if no replacement person can be provided (for the duration of the programming period plus the possible auditing legal period).
In general, in addition to the unsubscribe link of a usual MailChimp campaign, a user can find the link “update subscription preferences” in the footer. That link provides access to his/her profile and set of data recorded in the corresponding MailChimp mailing list, with the possibility to amend preferences and privacy elements.
In any case, any user or person receiving email from the FSU can contact the FSU secretariat to request further assistance on those aspects (by phone, email or at the FSU premises).
 
People can register to be part of the FARNET mailing lists in different ways:
  • On a voluntary basis:
    • By clicking on the “Subscribe” button on the homepage
    • By clicking the link “Subscribe to the FARNET flash” on the Newsletter page  in the Library.
      For both, a simple form is displayed with 5 mandatory information fields (gender, first name, last name, email address and country). The organisation name is optional and can help FSU in targeting information more relevant to the user if needed.
  • On the basis of legal/business relationships or on a legitimate interest basis (e.g. after a contact made at an event with the FSU or FARNET team, or after a direct request made by a user without using the online form). New registrations are then manually processed by the FSU. In that process, supplementary information may be collected like postal address (for instance to send out the paper FARNET magazine, or to display contact addresses of Managing Authorities, Intermediate Bodies, FLAG organisations) and phone details or social network/web links. However, this information may not be considered as personal information if, for instance, it is referring to the organisation only.
In both ways, when the user is added to the MailChimp mailing he/she receives an automated notification email with the GDPR information and privacy information.
 
3.4 Participation in (online) surveys
The personal data collected depends on the type of survey and can contain supplementary information when relevant. Otherwise, only country and organisation type will be collected, and personal information may then be optional or anonymised.
 
3.5 Personal data offered for job applications
Personal data offered in the context of job applications will be used solely for processing the application, unless consent was given for alerts on future job offers. The data will only be available to the FSU personnel handling the job offer.
The emails and personal data received at the FSU will be stored for 10 years for evidence purposes in case of juridical claims by the applicant. In case of hiring, the personal data will be shared with the social secretariat for FSU and DEVNET EEIG.
 
3.6 Conference and event participation
In order to participate in events organised by FARNET, registration is required for organisational purposes (venue size, catering services, inform participants of programme updates, etc.). Registration forms will contain a section to allow participants to subscribe to further communications by FSU, or to remove their data once the event has taken place (this is the default option). For each event, several emails may be sent as part of the communication agreement: save-the-date, posting of the tentative programme, abstract submission calls, closing of the early bird or final programme, and the closing email with links to pictures taken and download links for presentations.
During our events, pictures/films can be taken which can be communicated to the participant, used in the FARNET or FSU annual reports and other FARNET publications, or posted on our website. If you do not want your pictures to be published, you can send a request for the removal of photographs or films to the email address used for event administration or to info@farnet.eu. Photos in which the requester are shown will be removed from our websites and servers; for films, the film segment will be cut out or the film deleted if the requester is clearly visible.
 
3.7 Visitor tracking on website and cookies
The FARNET website makes use of the IT support and system (Webgate servers) of the European Commission. 
The privacy and tracking system (cookies) is managed under the European Commission Cookies management system.
A number of our pages use cookies to remember:
  • your display preferences, such as contrast colour settings or font size
  • if you have already replied to a survey pop-up that asks you if the content was helpful or not (so you won't be asked again)
  • if you have agreed (or not) to our use of cookies on this site.
Cookies are also stored by Europa Analytics (based on the PIWIK open source solution), the corporate service which measures the effectiveness and efficiency of the European Commission's websites on EUROPA. The lifetime of the cookies on the FARNET website has been set to 55 hours as recommended by the IT infrastructure of the Next Europa servers; this doesn’t prevent you from cleaning up any out-dated cookies in your Internet browser.
Enabling these cookies is not strictly necessary for the website to work, but it will provide you with a better browsing experience. You can delete or block these cookies, but if you do, some features of this site may not work as intended.
The cookie-related information is not used to identify you personally and the pattern data is fully under our control. These cookies are not used for any purpose other than those described here.
We may use the data to prepare statistics about the usage of the site so that we can understand how users interact with our site and improve our site content, products and services. For this, the data are anonymised.

4 Your rights as a data subject

A data subject is the natural person for whom personal data is processed. Each person has the right to be informed of what personal data is being processed, and to have access to their personal data.
As the data subject, you have the right to:
  • Request a copy of your personal details at any time to check the accuracy of the information held
  • and/or to correct or update this information.
  • You may also ask for your personal information to be deleted completely (your right to be forgotten). Simply send us an email at info@farnet.eu with your request, and we will act and reply you as soon as possible. Note that the GDPR stipulates that each request made must be logged.
Note that at all times, the person/user has the chance to personally unsubscribe from the FARNET newsletter or to a mailing list. An unsubscribe link is provided in every newsletter (see section 3.3-“Mailing lists and Newsletter registration” above).

5 How long do we keep your data?

Your personal data is kept as long as follow-up actions linked to the above-mentioned purpose are necessary within the duration of the FARNET programming period. The data related to contractual or administrative context may be kept until the end of the European Programming period (reference to 2014-2020) and its finalisation, plus any legal duration.
The legal duration related to usual FARNET activities outside employment related data for auditing purposes by the OLAF (European Anti-Fraud Office) or by the European Court of Auditors is up to five years after the official closure of the final report related to the management of FSU, contracted by the DEVNET EEIG for the European Commission.

6 The content management system (CMS) and technical environment

  • The FARNET website is created in a Drupal environment, hosted and managed by the services of the European Commission. For content management, several editors are appointed who need an account to be able to log in to and change a site. All session information and changes made by the editors are stored in the Drupal server.
  • The personal data related to the MailChimp mailing lists are manually managed via the FARNET Drupal website, which is synchronised with the MailChimp mailing lists.
  • Any automated request for unsubscribing from the FARNET Newsletter is then synchronised with the MailChimp system, plus a request sent to FSU for a manual action on the Drupal central system. 
  • This is a multiple step process. Should urgent action be required, it is recommended to contact the FSU team at info@farnet.eu or via any means as indicated in the section 8-“Website operator and data controller” below.

7 Updates to the Privacy Policy

We will update our Privacy Statement whenever necessary. Unless, and until, you object in writing by contacting us at info@farnet.eu, all changes will apply to the existing information about you that FSU already holds, and the personal information collected from the effective date of the revised Privacy Statement. Your use of our website following the effective date of any revision will constitute your acceptance of the terms of the updated Privacy Statement.

8 Website operator and data controller

In case you have questions, comments or objections related to this Privacy Statement, or on your rights, you can contact us by email info@farnet.eu, by phone +32 (0)2 613 26 50; or at FARNET Support Unit - Rue Belliardstraat, 40 - 1040 Bruxelles/Brussel - Belgium.
 
8.1 Contact details of the person responsible for technical matters at FARNET Support Unit: 
  • Name: Kariger, First name: Sabine
  • Function: Contract Manager
  • Postal address:
       The FARNET Support Unit
       Rue Belliardstraat, 40
       1040 Bruxelles/Brussel
       Belgium
  • Phone: +32 2 613 26 50 
  • email address: sabine@farnet.eu). 
8.2 Contact details of the person in charge of the Data Protection for the European Commission:
Complaints, in case of conflict, can be addressed to the European Data Protection Supervisor: https://edps.europa.eu 
Publication date: 
21/06/2019