Context

The University of Namur organizes training courses leading, where appropriate, to the award of a university certificate. For the purposes of managing, implementing and promoting these training courses, the University of Namur processes the data of people who register for training courses as well as the teachers associated with them and trainers external to the University of Namur.

Categories of personal data processed and purposes of use

For the purposes of training management, according to the modalities and specificities of the latter, the University of Namur is likely to use the following categories of data:

  • Registration data [category grouping the following type of data: date of registration, purpose of registration ...]
  • General identification data [category grouping the following type of data: surname, first name, postal address, e-mail addresses, copy of identity card, passport photograph, telephone number ...]
  • Identifiers assigned by public authorities [category grouping the following type of data: NISS, passport number, identity/residence card number, national register or national register bis number, driving license number, license plate...].
  • Identifiers assigned by UNamur [category grouping the following type of data: student number, internal matricule number, eID for access to internal resources, access card identifiers, student card number ...]
  • Personal characteristic data [category grouping the following type of data: date of birth, gender, place of birth, marital status and nationality, residence status in Belgium, mother tongue, languages spoken, possession of a driving license ...]
  • Social data [category grouping the following type of data: data relating to the receipt of a study allowance from the Wallonia-Brussels Federation, social assistance from a CPAS, family allowances, the granting of a scholarship by the University or another entity ...].
  • Professional data [category grouping the following type of data: data relating to profession or professional activities, function in an entity outside the University, professional affiliations...]
  • Data relating to the function exercised (student, unemployed, active, ...) in the context of the application of a possible preferential rate
  • Data relating to the student's school and academic career [category grouping the following type of data: data relating to the student's academic career, annual program - teaching units attended -, grades, credits, honors, diplomas obtained, country of issue of diploma(s), jury opinions, disciplinary decisions and appeals, end-of-study work, internships completed...]
  • Data relating to teaching and pedagogical activities [category grouping the following type of data: data relating to the organization of work groups, formative activities, examinations, course evaluations, tests offered as part of success support, assignments completed ...]
  • [For external trainers] Professional data [category grouping the following type of data: data relating to profession or professional activities, function in an entity outside the University, professional affiliations...]
  • Banking and financial data of individuals [category grouping the following type of data: bank account number, IBAN code, VAT details ...]
  • Payment data[category grouping the following type of data: data relating to a transaction, amount, date of payment, debtor, creditor, purpose of transaction ...]
  • Data linked to IT resources[category grouping the following type of data: data linked to user accounts, electronic communications, use of applications and software, use of storage tools in IT resources made available ...]
  • Data linked to the taking of sounds, photographs or videos [category grouping the following type of data excluding video surveillance images and passport photo: recordings, metadata associated with recordings ... ]

These data are used for:

  • Training management
    • Registration management (covering management of the online registration process, management of the registration gauge, issuing a nominative list of participants, issuing invoices for registration fees)
    • Management of the organization of training activities (this may include audio or video recordings if justified by health conditions or pedagogical considerations) and communication with participants during training (information, premises, schedules, changes, ...)
    • Granting, managing and securing access to IT and documentary resources (participant registration on a platform (Moodle, WebCampus, ...), access to libraries, ... )
    • Managing the issuing of certificates and attestations
  • Managing any disputes
  • Producing training-related statistics
  • Managing and assessing the quality of training, infrastructure and services offered to participants
  • Promoting the training courses offered by the University of Namur
.

Basis for lawfulness of data processing

public in terms of services to the community and it is on this basis (Article 6, (1), e of the RGPD) that it processes the data of participants and trainers for the purposes of training management.

The management of disputes.The University of Namur has a legitimate interest in being able to manage its litigation and, where appropriate, assert rights in a pre-litigation or litigation context (Article 6, (1), f of the RGPD).

The production of statistics relating to training. The University of Namur has a legitimate interest in being able to acquire better knowledge of its training activities and the needs related to the organization thereof (Article 6, (1), f of the RGPD).

The management and evaluation of the quality of training, infrastructure and services offered to participants. In addition, the University of Namur has an obligation to implement a quality approach as part of the exercise of its missions, which may involve the use of training-related data for the purposes of self-evaluation and external evaluation (Article 6, (1), e of the RGPD).

When the University of Namur uses data for the constitution of the mailing list of the request to participate in a survey, it is based on a legitimate interest which is to be able to contact people who can give useful feedback in view of the purpose of the survey, knowing that these people are former participants/trainers in training courses organized by the University and that they can indicate at any time that they no longer wish to be contacted again in the future to participate in this type of survey (Article 6, (1), f of the RGPD).

When the University of Namur processes and analyzes the responses given, it does so on the basis of a legitimate interest, which is to be able to assess the suitability of its training courses in relation to the needs of the public, and this as part of a continuous quality approach to its training offer (Article 6, (1), f of the RGPD).

The promotion of training courses. The University of Namur considers that it has a legitimate interest in being able to promote its activities to people who have registered for training courses offered by the University, bearing in mind that these people may at any time object without reason to the sending of further communications concerning the training offer (Article 6, (1), f of the RGPD).

Categories of persons concerned

  • People requesting information about training courses
  • Participants in certification courses and requesting registration for these courses
  • Former participants
  • Trainers from outside the University of Namur
  • Members of a mailing list
.

Data recipients

Data are accessible only to faculty, research center or institute staff involved in the organization of training, as well as to trainers, to the extent necessary for the performance of their duties. For accounting or IT management purposes, data may be accessed and processed within other University departments by University of Namur staff duly authorized to access and/or process it. Furthermore, participants' data may be communicated to other participants as part of and for the purposes of carrying out the activities proposed during the course.

The University of Namur uses external IT service providers for occasional support and hosting services who may therefore be required to process participant or trainer data, but only for the purposes of providing the agreed services and on the instructions of the University of Namur. If the University of Namur also offers access to licensed Microsoft Office 365 products, this implies services and hosting of user data carried out by Microsoft.

Data may furthermore be transmitted to third parties (other higher education institutions or institutions in the event of co-organization of training programs) insofar as such transmission is necessary to achieve the purposes of the processing. Data recorded in the accounts may also be accessed by external auditors (auditors, etc.). Data attesting to a registrant's participation in a training course may be transmitted to his/her employer/public authority when the latter is responsible for paying for the training.

Data sources

The data processed is provided by participants / trainers or generated when using university resources.

Some data may be provided by the participant's / trainer's employer or an organization with which they are affiliated, particularly if registration is carried out by a member of that organization and not directly by the participant.

In the case of co-organization of a training program with another institution, data relating to the student may also be provided by the partner institution.

Treatment features

Data is kept for the time required for training and the issue of attestations/certificates. This duration is defined taking into account the need to be able to reissue, on request, a certificate after completion of the training.

In addition, retention periods are a function of organizational considerations (for managing access rights to resources, sending requests for surveys or training offers), security considerations (the detection and remediation of computer incidents) and legal considerations (the period during which the University of Namur may be held to account, or until the end of any litigation proceedings). Insofar as the payment of registration fees enters the accounts of the University of Namur, this data is kept for the legal retention period.

Rights of persons concerned

The persons concerned by a data processing have rights which are described on the page www.unamur.be/fr/vie-privee.