Information Note concerning the processing of personal data by House of Training
The European General Data Protection Regulation 2016/679 of 27 April 2016 (hereinafter referred to as "the GDPR") protects the privacy and rights of individuals, and this is a matter of prime importance for House of Training too.
This Information Note (hereinafter referred to as "the Note") is designed to lay down the conditions in which House of Training processes personal data of its clients, of persons showing an interest in its activities, of suppliers/service providers working for it, where appropriate, and of partners with whom it sets up training programmes.
The Note informs you what processing is carried out in relation to your personal data by House of Training, registered in the Luxembourg Trade and Companies Register under number G22, established at 7, rue Alcide de Gasperi, P.O. Box 490, L-2014 Luxembourg, in its capacity as controller, during your contractual relationship with it in accordance with the GDPR.
1. What types of personal data are processed?
The term "personal data" means any information enabling a natural person to be identified, directly or indirectly (hereinafter referred to as "the Data").
In order to offer a comprehensive quality service, House of Training processes different categories of personal data:
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Personal identification data enabling us, among other things, to get in contact with you (for example: surname, first name, address, date of birth, nationality, telephone number, e-mail address, where necessary),
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personal data relating to your training at HoT (contract numbers, names of participants, certificates of participation and of success in exams, etc.), enabling us to fulfil our commitments and obligations (including registrations for specific sessions on the basis of the participant’s consent), namely delivery of the training and performance of the tasks resulting therefrom,
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personal data relating to your professional career path, in the case of customised training,
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data enabling us to organise your travel abroad, in the case of participation in so-called ATTF training (passport, visa, nationality, …),
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data relating to your image, enabling us, on the basis of your express consent given in advance of a training session, to film and/or record you and to use those data in the context of our training activities. You will be notified of the precise purpose at the time when your consent is requested,
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data gathered by CCTV which concern your image,
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data relating to your visits to our premises involving use of our car park (vehicle licence plate, times when a parking space is used).
With a view to respecting the principle of minimisation of data, Data are only collected, processed and kept if they are relevant and necessary for the performance of our services.
2. On what basis, and why, are your Data used?
The processing of Your Data is necessary for the conclusion and performance of your Contract with House of Training and for the purposes of compliance with the legal requirements to which House of Training is subject.
The Data that you entrust to us enable us:
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to manage and deliver our training, whether face-to-face with the learners or remotely,
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to transmit to our partners and subcontractors the information necessary for the training to be provided,
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to manage our contractual relationships with our clients,
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to inform our clients about new products or developments which may be useful to them and to offer them global advice in respect of training,
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to keep persons who have indicated their interest therein, by express consent (e.g. by signing up to receive our newsletter), informed of our activities and of our new products or developments,
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to ensure the safety of our in-house staff and of visitors
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to manage the operation of the car park whenever this is used,
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to transmit the requisite information to those administrative authorities that are entitled by law to receive it, such as the tax authorities.
3. Who has access to your data?
Your Data are used by persons employed in our various departments, strictly within the framework of the tasks entrusted to them.
Your Data are also transmitted to the following addressees in the context of the performance of their contract with House of Training:
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Our institutional partners (administrative authorities, professional chambers and associations, federations)
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Our private-sector partners (e.g. schools, other training centres, etc.) with whom we develop joint offers
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our subcontractors (such as trainers, IT hosting platforms for e.g. e-learning, etc.)
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our other service providers used to enable our business to function smoothly (providers of IT services, printing services, insurance companies).
In accordance with the contractual provisions and the applicable data protection legislation, House of Training's partners and subcontractors undertake to process the personal data solely for the purposes of performance of their contractual obligations vis-à-vis House of Training and to take the requisite measures to ensure that the confidentiality of those data is respected by their staff.
Where a learner who is employed has himself/herself registered for training in his/her own name, his/her employer will not have access to any certificates of attendance or of success in examinations, or the results of examinations, and shall thus be required, in order to receive them or have sight of them, to go directly through the learner.
4. For how long are the Data kept?
Whether you are a client (private individual or corporate entity) or a supplier, your Data will be kept throughout the duration of your contract, and, after it comes to an end, for the period necessary for the performance of our legal and/or contractual obligations, or, where the processing was based on your consent (given e.g. at the time of requesting information about our training courses), until such time as you request us to cease processing them.
Personal data necessary for the issuance of training certificates shall be kept for a period of 10 years.
5. What are your rights?
The data protection rules provide, within the limits prescribed by the applicable legislation, that you are entitled, as a "data subject", free of charge:
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to demand access to your personal data
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to demand rectification or erasure of the data
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to demand restriction of processing of the data
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to object to use of the data for marketing purposes
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to demand the portability of your data.
These rights may be exercised by sent to the following address: gdpr@houseoftraining.luHouse of Training reserves the right to request you to complete the dedicated form* and provide it with a scanned version/paper copy of your identity card, so that we may verify your identity before dealing with your request.
You also have the right, in the event of any doubt concerning compliance by House of Training with the applicable data protection rules, to lodge a complaint with a supervisory authority such as the Commission Nationale pour la Protection des Données (National Data Protection Commission - CNPD), having its headquarters at 15 Boulevard du Jazz, L-4370 Belvaux.
Protection against fraudulent requests for personal data
House of Training points out that no request for personal data will be made by telephone, whatever the purpose.
Any solicitation claiming to come from the House of Training in this context must be considered fraudulent.
We invite our customers and partners not to respond to such requests and to report any suspicious incidents to the following address: gdpr@houseoftraining.lu.
This measure is intended to strengthen the security and confidentiality of the data you entrust to us, in accordance with the provisions of the General Data Protection Regulation (GDPR).
6. How to contact us?
For any questions or requests regarding personal data protection, all you need to do is send an email to gdpr@houseoftraining.lu.
* Sent by our team
Version updated as of 20/11/2024