Your personal data are processed by Febelfin asbl/vzw (non-profit association), Bd Roi Albert II/Koning Albert II-laan, 1210 Brussels. In most cases, Febelfin asbl/vzw processes your data together with its five member associations: the Belgian Bankers and Stockbroking Firms’ Association (ABB/BVB), the Belgian Asset Managers Association (BEAMA), the Credit Association (UPC/BVK, Union professionnelle du Crédit/Beroepsvereniging van het krediet), the Belgian Leasing Association (BLA) and the Belgian Association of Stock Exchange Members (BASEM). In concrete terms, this means that Febelfin asbl/vzw and the five member associations are jointly responsible for the processing of your data. They are referred to hereinafter as ‘Febelfin’.
In some cases, your personal data is processed only by Febelfin asbl/vzw. This is expressly indicated in this policy, so that it is clear to you.
If you have any questions about the processing of your personal data by Febelfin, please contact us via privacy@Febelfin.be
Febelfin aims to process your personal data in a manner that is legally correct and secure. This statement is intended to inform you clearly about which personal data we (might) process (request, collect, store, use, etc.) and for what purposes we do this. We also explain how, if you wish, you can exercise your rights with respect to Febelfin.
When we refer to personal data below, we mean mainly identification and contact details such as your surname, first name, address, telephone number, e-mail address, position within your organisation, language, gender, etc.
This statement concerns the processing of the personal data of natural persons who make contact with Febelfin. It is not intended for Febelfin staff, who are informed in more detail about the processing of their data in a statement drawn up specifically for this purpose.
In practice, a natural person can come into contact with Febelfin in several capacities or roles. This capacity is extremely important. It determines for which purpose which data are processed, the basis for the processing, how long the data are kept, with whom they are shared and what rights you have.
A natural person may have the following capacities with respect to Febelfin:
We explain below what the data processing involves for each of these capacities or roles.
The common factor as regards these capacities is the way in which you, as a data subject, can exercise the rights granted to you by the regulations. This means that this is the same for all capacities. This aspect is explained in more detail at the end of this statement.
Except when this is expressly indicated, your personal data are processed jointly by Febelfin asbl/vzw and its member associations. Febelfin asbl/vzw and its member associations have concluded a mutual arrangement for the joint processing operations, which you can find here.
Your personal data are processed by Febelfin if you are a staff member of a (current or former) Febelfin member.
Purposes
If you work for a Febelfin member, we process your data in the context of the services that Febelfin provides to its members (communication, sharing information, consulting Febelfin-Net, participation in working groups, invitation to events, mandates, etc.).
Basis
The basis for this processing is Febelfin’s legitimate interest, as a professional federation (or association), to ensure communication between its members.
Personal data categories
In this respect, the following categories of personal data are processed:
Personal identification data (surname and first name, address, contact data)
Professional contact data (title, professional telephone number, e-mail address and postal address, etc.)
Position data, such as institution (Febelfin member), position within the institution
Membership of working groups within Febelfin.
How do we obtain your data?
In principle, we obtain your personal data from you, in particular when you use the application offered by Febelfin. Your employer may also pass on your data to us.
Recipients
Your personal data are accessible to other Febelfin members in the context of the services provided by Febelfin.
Retention periods
These data are kept for as long as you are a staff member of a Febelfin member and have an account on Febelfin-Net. Consequently, the end of your relationship with a Febelfin member does not automatically mean that your personal data are deleted. You can request this using the periodic message that you receive to validate your data in Febelfin-Net.
If you do not work for a Febelfin member but you are an individual with whom Febelfin comes into contact in the context of its mission and activities (such as politicians, cabinet staff, journalists, academics, supervisors and others), we process your personal data to be able to communicate with you, share information with you and, where appropriate, involve you in Febelfin activities.
Purpose
In this case, your personal data are processed with a view to representing and promoting the interests of the financial sector.
Basis
The basis for the processing of these personal data lies in the legitimate interests of Febelfin and its member associations, as representatives of the financial sector, to promote and monitor the interests of the financial sector (freedom of organisation).
Personal data categories
The following categories of personal data are processed:
Personal identification data (surname and first name, title, position, address, contact data, etc.)
Personal particulars (age, gender, etc.)
Professional activities (position within the company or organisation, job title, type of activity of the company or organisation, etc.)
Membership of a professional organisation, political party or trade union
Public mandates
Personal data that reveal political views, ideological convictions or membership of a trade union.
How do we obtain your data?
In principle, the data are not obtained directly but by consulting public sources.
Recipients
These data are processed exclusively internally, within Febelfin. They are not shared with third parties, except for cases where this is a legal obligation.
Retention periods
These data are kept for as long as you are relevant for the mission and activities of Febelfin. A message is sent to you every year to verify your data. This also gives you the opportunity to delete your data.
Each person can subscribe to one of the newsletters sent by Febelfin. In this case, your personal data will be processed for the management of your subscription and the delivery of the newsletter. Exceptionally, we may also use this data to provide you with other similar information. You always have the option to unsubscribe.
Purpose
The purpose of this processing is to send the newsletters to which you subscribe.
Legal Basis
The legal basis for this processing is Febelfin's legitimate interest in informing interested individuals about its mission, services, and activities.
Categories of Personal Data
The categories of personal data processed are:
Personal identification data (name and surname, title, contact details such as address and email address)
Subject of the inquiry, request, or contact
How do we obtain your data?
The data are primarily obtained directly from you when you subscribe to the newsletter.
Recipients
Your data will be processed internally by the departments that require it for the delivery of the newsletters, particularly the communication department.
It is possible that processors may be involved in this process, always under the control and responsibility of Febelfin.
Retention Periods
The data will be kept as long as you are subscribed to or registered for the newsletter, with the understanding that you always have the possibility to unsubscribe and no longer receive the newsletter in that way.
Like every natural person, you have the possibility of indicating that you wish to be kept informed of Febelfin’s activities by a means other than via a newsletter.
Purpose
In that case, your personal data are processed to inform you of Febelfin’s activities, political, economic and legal current affairs relevant for financial institutions and events organised within the sector.
Basis
The basis for this processing is the legitimate interest of Febelfin to inform those who are interested about its mission, services and activities.
Personal data categories
The following categories of personal data are processed:
Personal identification data (surname and first name, title, contact data such as address and e-mail address)
Your request to be kept informed of the activities
Any subjects in which you are interested.
How do we obtain your data?
In principle, the data are obtained directly from you when you make your request or express your interest.
Recipients
Your data are processed internally by the services that need them to keep you informed, in particular the communication service.
Retention periods
The data are kept for as long as you wish. This means that you have to possibility of indicating at any time that you no longer wish to be kept informed of the activities of Febelfin.
The data that you provide us with when registering for the event are processed to follow up your registration (invitation, confirmation of receipt, additional information about the event, billing (if appropriate), etc.). We can also store your feedback in the context of satisfaction surveys or any complaints.
For certain events, the participants receive a simplified list of participants with the surnames, first names, positions and organisations of the participants.
During certain events, pictures of the general atmosphere and photos of participants may be taken to illustrate and support the activities and mission of Febelfin.
Purpose
The purpose of this processing is the organisation and management of events by Febelfin, including invitations and registration, and related direct mailing.
Basis
The basis for this processing is Febelfin’s legitimate interest, as a professional federation, to provide services for its members.
Insofar as an image of the data subject is involved, in principle the consent of the data subject is required, both to take and to publish the image.
Personal data categories
We process the following data:
Personal identification data (surname and first name)
Other identification data (car number plate for parking, etc.)
Professional data (job title, position within the Febelfin member company, etc.)
Images (photo)
Personal data on health.
How do we obtain your data?
In principle, the data are obtained directly from you. If and insofar as data are obtained via your company, you are informed of this in a confirmation e-mail.
Recipients
Your data are processed internally by the services that need them to organise the event.
A processor may be called upon for the organisation of events. This is always done under the control and responsibility of Febelfin.
For an event that is organised with another party, your data are shared with this party, albeit only for the registration for the event and the related follow-up.
Retention periods
The data obtained in the context of event management are kept for no longer than one month after the end of the event.
If you contact Febelfin, for example with a request for information (e.g. contact point for rent guarantee), we use your data exclusively in the context of the processing of your request.
Purpose
The purpose of this processing is communication with third parties in relation to a question, request or other contact.
Basis
The basis for this processing is the legitimate interest of Febelfin to answer the question or respond to the request or any other form of contact made by the data subject.
Personal data categories
We process the following data:
Personal identification data (surname and first name, title, contact data such as address and e-mail address)
Subject of the question, the request or the contact.
How do we obtain your data?
We obtain your data when you ask a question or make a request via the contact page provided for this purpose or via e-mail.
Recipients
Your data are shared internally by the services that need them to be able to answer your question or respond to your request.
Retention periods
Your data are kept for as long as is necessary to respond to your question, request or contact. Partly to enable follow-up, they are kept for a maximum of one year after contact has been made with Febelfin.
Febelfin asbl/vzw offers a ‘bank searches’ service. This service can be used to check whether an account has been opened by or in the name of a person at a financial institution that is a member of Febelfin. In this respect, the personal data of the natural person submitting the request have to be processed.
These data are only processed by Febelfin asbl/vzw (and not by its member associations). If you request a bank search, Febelfin will process your personal data and the personal data of the individual mentioned in the request in accordance with the procedure described on the website.
Purpose
Your personal data are processed to enable Febelfin to transfer your request to its members and to check whether an account has been opened by or in the name of the person that you mention in your request, and to share the result of this.
Basis
The basis for this processing is the legitimate interest of Febelfin to offer a service to the public in order to check whether an account has been opened by or in the name of a particular individual.
Personal data categories
The following personal data are processed:
Identification and contact data (surname and first name, address and e-mail address)
Financial data (where appropriate, VAT number).
How do we obtain your data?
Your personal data are obtained from you, as the party requesting the bank search.
Recipients
In principle, your personal data are only shared with the staff of the specific service of Febelfin asbl/vzw who are tasked with this, as well as the banks that are Febelfin members.
As in other cases, it is possible that, where appropriate, they have to be shared with the government in the context of a specific investigation, insofar as they are still available at Febelfin.
Retention periods
The personal data are kept by Febelfin as long as is necessary to provide the service and at the latest for 11 months after the submission of the request.
Febelfin offers a ‘bank searches’ service that can be used to check whether an account has been opened by or in the name of a person at a financial institution that is a member of Febelfin. In most cases, these requests relate to a natural person who has passed away, which means that the privacy protection regulations do not apply. Nevertheless, it is possible that the request may relate to a living natural person. This is the case in particular when a request is submitted by a temporary administrator or a CPAS/OCMW (public welfare centre) that is authorised to do so. In these cases, the personal data of the (living) natural person who is the subject of the (request for the) bank search have to be processed.
These data are only processed by Febelfin asbl/vzw (and not by its member associations).
Purpose
Your personal data are processed to enable Febelfin to check with its members whether an account has been opened by you or in your name and to share the result with the party making the request.
Basis
The basis for this processing is the legitimate interest of Febelfin to offer a service to the public in order to check whether an account has been opened by or in the name of a particular individual.
Personal data categories
The following personal data are processed:
Identification data (surname and first name, place and date of birth, address of the person to be protected/investigated)
National register number
Marriage or current form of co-habitation
Any other information that can make the search more efficient (in addition to national register number and civil status, etc.) such as identification data other than the national register number
(In the case of a request from a temporary administrator:) copy of the full decision from the court appointing the temporary administrator
(In the case of a request from a CPAS/OCMW:)
power of attorney from the person being investigated and legalised signature
a recto-verso copy of the identity card of the person being investigated.
How do we obtain your data?
Your personal data are obtained from the person requesting the bank search.
Recipients
In principle, your personal data are only shared with the staff of the specific service of Febelfin asbl/vzw who are tasked with this, as well as the banks that are Febelfin members. As in other cases, it is possible that, where appropriate, they have to be shared with the government in the context of a specific investigation, insofar as they are still available at Febelfin.
Retention periods
The personal data are kept by Febelfin as long as is necessary to provide the service and at the latest for 11 months after the submission of the request.
Febelfin offers a ‘bank searches’ service. This service can be used to check whether an account has been opened by or in the name of a person at a financial institution that is a member of Febelfin. In certain cases, a request like this can be submitted on behalf of other natural persons. In this case, the personal data of the natural person or persons on whose behalf the bank search is requested have to be processed.
These data are only processed by Febelfin asbl/vzw (and not by its member associations).
Purpose
Your personal data are processed to enable Febelfin to share the request submitted on your behalf to check among its members whether an account has been opened in the name of your testator and the result of this check with the person acting on your behalf for this request.
Basis
The basis for this processing is the legitimate interest of Febelfin to offer a service to the public in order to check whether an account has been opened by or in the name of a particular individual.
Personal data categories
The following personal data are processed:
Proof of the capacity of the person on whose behalf the request is submitted (heir): affidavit, certificate of succession or certificate/deed of inheritance
Recto-verso copy of the identity card of the person on whose behalf the request is submitted
Power of attorney of the person on whose behalf the request is submitted
How do we obtain your data?
Your personal data are obtained from the person requesting the bank search.
Recipients
In principle, your personal data are only shared with the staff of the specific service of Febelfin asbl/vzw who are tasked with this, as well as the banks that are Febelfin members.
As in other cases, it is possible that, where appropriate, they have to be shared with the government in the context of a specific investigation, insofar as they are still available at Febelfin.
Retention periods
The personal data are kept by Febelfin as long as is necessary to provide the service and at the latest for 11 months after the submission of the request.
You can visit the Febelfin asbl/vzw website(s) at any time. In that case, Febelfin asbl/vzw can store certain data using cookies. A cookie is a small file that is sent by an internet server and stored on the hard disk of your computer. This file contains information about your visit to our website. Cookies are intended to improve your browsing experience during a future visit to our website and to gather general statistics regarding the quality and use of the website. Cookies are not, under any circumstances, used for commercial or direct marketing actions.
Owing to the specific importance of this, we refer you to the Febelfin asbl/vzw cookie policy in this respect.
In order to be able to carry out its activities, Febelfin needs products and services. These are provided by various natural persons and/or companies. You may be a service provider yourself or work for a company that provides a product or service for Febelfin. In that case, too, your personal data are processed.
Purpose
Febelfin processes your personal data to follow up the service provision and any related comments or complaints. As such, your data are processed in particular for general supplier management, including accounting processing, management of disputes and legal proceedings, the collection or transfer of claims and the protection of the rights of Febelfin in general.
Basis
The basis for the processing of your data depends on your status as a supplier.
If the supplier is a natural person, the processing is based on the fulfilment of the agreement reached between Febelfin and the supplier.
If the supplier is a legal entity, the processing is based on the legitimate interests of Febelfin to carry out its activities and in that context, to process the data of the natural persons who act as the representative and/or contact person of the suppliers with which Febelfin concludes an agreement.
Personal data categories
We process the following data:
Supplier identification data (including the identification data of representatives)
Financial data
Data relating to the services provided or the products supplied
How do we obtain your data?
In principle, we obtain your data from you when the services are provided or the products are supplied.
Recipients
The data are shared internally (within Febelfin) to the services that need them for the operation or needs of their service. This depends on the services or products provided by the data subject. In particular, these data are made available to the accounting department that is responsible for payment.
In principle, your data are not shared with others, unless this is necessary for legal reasons, such as compliance with the VAT regulations.
Retention periods
Your personal data are kept for up to 10 years after the last contact that we had with you.
Any natural person can visit the Febelfin offices. In this context, your personal data are processed by an external company that is responsible for receiving visitors, without intervention by Febelfin. In addition, pictures are taken of you, as a visitor, by Febelfin when you enter the floors on which the Febelfin entities are located.
Purpose
When you visit Febelfin, we process your personal data in the context of the security of the building.
Basis
The basis for this processing is Febelfin’s legitimate interest to secure the buildings in which it is located.
Personal data categories
The following data categories are processed:
Identification data
Images.
How do we obtain your data?
In principle, we obtain your personal data from you, further to your visit to our buildings.
Recipients
Your data are processed by Febelfin for exclusively internal purposes of building surveillance.
Retention periods
Febelfin keeps your personal data no longer than is necessary for the intended processing purposes. In principle, your data are kept for no longer than one month.
If you apply for a vacant position or spontaneously, Febelfin processes the personal data that you provide to follow up your application.
Purpose
Your personal data are processed by Febelfin asbl/vzw to assess and follow up your application.
Basis
To the extent that a job application is intended to examine whether or not an agreement can be concluded, personal data have to be processed in order to take pre-contractual measures.
Personal data categories
The following categories of personal data are processed:
Identification data (surname, first name or names, address, etc.)
Personal data (place and date of birth, nationality, gender, telephone number, e-mail address, hobbies and interests, etc.)
Photograph, if this is provided voluntarily
Data relating to professional experience (profile, data on previous employers, termination of previous employment and work provided, special projects, etc.). If references are included in the CV, this may lead to an examination of these references
Data relating to training (diplomas, certificates, traineeships, special training courses, etc.)
Language knowledge
If applicable, a work and/or resident permit for the European Economic Area (EEA)
Any other data that may be provided with the job application, in the CV or cover letter, regarding the performance of the job
Digital assessment via the internet (presence on social media), to the extent that this presence is public
All other personal data (other than those mentioned above) that have to be processed pursuant to the law.
How do we obtain your data?
In principle, the data are obtained from you, either further to the job application for a vacant position, or further to a spontaneous job application.
Recipients
Your personal data are only processed internally by staff in the Febelfin hr department and the management with regard to the position for which you are applying.
Retention periods
Your personal data are in principle only kept for the period of time necessary to assess your application. This means that if your application is not retained, your data are in principle deleted. However, they are kept for up to six months after the conclusion of the application procedure in order to take into account unforeseen circumstances in the context of the recruitment.
To the extent that Febelfin wishes to include your data in a recruitment reserve, it requests your consent to do so.
Where are your data processed and stored?
Febelfin never shares your personal data with or sells your data to third parties who process these data for their own commercial purposes.
For certain aspects of the processing of your personal data, such as ICT and logistics, Febelfin may, however, call upon external partners designated as ‘processors’. These are companies that process your data in line with a clearly determined framework and in accordance with an assignment defined by Febelfin (asbl/vzw). These companies are in principle located in Belgium or in the European Union. Should this, exceptionally, not be the case, Febelfin takes the necessary measures to ensure that your data are passed on to the recipients in third countries in accordance with the applicable framework.
What rights do you have in respect of Febelfin?
The regulation grants you a number of rights. We are confining ourselves here to the rights that apply in your relationship to Febelfin.
Right to object
If Febelfin processes your personal data on the basis of its legitimate interest as described above, you have the right to object to this processing. Bear in mind that this objection may mean that Febelfin may not be able to answer your question or respond to your request or provide any other service given the lack of personal data.
Right of access
If you would like to access your personal data that we process, you can let us know. If you exercise this right of access, Febelfin will give you an overview of the data concerning you that it keeps and processes.
Right to rectification
If you notice that the data that we have received from you are no longer correct, you can let us know. We will make the necessary adjustments or supplement the data as quickly as possible.
Right to erasure
If you no longer wish Febelfin to process your data, you can contact us at any time and ask us to have your data erased.
Transferring your data
You have the right to ask Febelfin to transfer the personal data that you have provided to Febelfin to you or directly to a third party.
If you wish to exercise one of the above rights or submit a complaint about the way in which Febelfin processes your data, you can contact Febelfin by:
e-mail: privacy@Febelfin.be
letter via Febelfin (asbl/vzw), Bd Roi Albert II/Koning Albert II-laan 19, 1210 Brussels
Please be as specific as possible when exercising your rights. This will enable Febelfin to deal with your question practically and correctly.
Febelfin will verify your identity to prevent other people from exercising your rights.
If you would like more information about the processing of personal data in general or if you disagree with the position of Febelfin, you can contact the Data Protection Authority, rue de la Presse/Drukpersstraat 35, 1000 Brussels – e-mail address contact@apd-gba.be and telephone number +32 (0)2 274 48 00 and +32 (0)2 274 48 35), where you can submit a complaint if you wish.