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Data protection notice SA SPIE and related companies

Data protection notice

SPIE SA and all its affiliated companies

  

1. Introduction

Headquartered at 150-152 Rue des Deux Gares, 1070 Anderlecht, and registered in the Crossroads Bank for Enterprises (central business register) under company number  0434.499.028, SPIE SA attaches the utmost importance to the collection and to the secure, transparent and confidential processing of your personal data. We are particularly keen to protect the data of our clients, subcontractors and suppliers, against loss, infringement, error, and unauthorised access or processing.

The purpose of this data protection notice is to inform you about the collection and processing of your personal data.

You are kindly requested to read this data protection notice carefully, as it contains important information on the way we process your personal data and the reason why we do so. 

By communicating your personal data, you explicitly declare that you have perused this data protection notice and explicitly accept the contents thereof as well as the processing itself.

 

2. Scope 

This data protection notice concerns all the services provided by us and more generally all the activities we carry out.


3. Controller and its commitments 
  

SPIE Belgium SA, having its registered office at 150-152 Rue des Deux Gares, 1070 Anderlecht, with company number 0434.499.028, is the controller of your personal data.    

ELEREP SA, having its registered office at 3 Lammerdries 2440 Geel, with company number 0883.559.538, is the controller of your personal data.

SA SPIE ICS Document Solutions SA, having its registered office at 431E Chaussée de Louvain, 13801 Lasne, with company number 0891.633.797, is the controller of your personal data

SA SPIE ICS Financial Solutions, having its registered office at 431C Chaussée de Louvain, 1380 Lasne, with company number 0461.260.338, is the controller of your personal data

SA SPIE ICS Cloud Solutions, having its registered office at 431C Chaussée de Louvain, 1380 Lasne, with company number 0643.953.997, is the controller of your personal data

SA SPIE ICS IT Talent Solutions, having its registered office at 431C Chaussée de Louvain, 1380 Lasne, with company number 0476.907.923, is the controller of your personal data

SA SPIE ICS Infrastructure Solutions, having its registered office at 431C Chaussée de Louvain, 1380 Lasne, with company number 0643.976.466, is the controller of your personal data

SYSTEMAT LUXEMBOURG SA, having its registered office at 30 Zare Ouest, L-4384 Ehlerange,  registered in the Luxembourg Trade and Companies Register under number B 110.102, is the controller of your personal data

SYSTEMAT EIS SA, having its registered office at 30 Zare Ouest, L-4384 Ehlerange, registered in the Luxembourg Trade and Companies Register under number  B 205.989, is the controller of your personal data

In collecting and processing your personal data, we comply with the Belgian legislation on personal data protection as well as the General Data Protection Regulation (GDPR) as of its entry into force on 25 May 2018.

 

4. Personal data 
  

SPIE Belgium SA processes the personal data of:

  • Its employees, including applicants, former employees, temporary workers who work under the supervision of SPIE Belgium as independent contractors and trainees. This processing is described in greater detail in the Employee Data Protection Policy;
  • Its clients;
  • Its subcontractors and suppliers;
  • Third parties (visitors to our worksites / offices / our websites, new clients/prospects, contact persons in our sector, contacts in the network, experts, etc.).

Depending on your activities and the relations with our company, you provide the following personal data:

  • Your identity details and particulars (name, sex, title, date of birth, e-mail address, landline number, mobile telephone number, nationality, identity photo, etc.);
  • Your financial and invoicing data (bank account number, etc.);
  • Your education, training courses, certifications, permits (residency, work permit, etc.).

For certain particular legal obligations (electronic attendance registration, 30bis declaration of work), you may have to provide additional data in order to record your presence (such as E-ID data, LIMOSA number).

We would like to point out that you bear responsibility for all the data you provide and we count on their accuracy. If your data are no longer up to date, please inform us immediately.

You are not required to communicate your personal data, but bear in mind that it will not be possible to provide certain services or to work together if you do not consent to the collection and processing of certain data.

 

5. Processing purposes and legal basis
  
5.1. Client data

As part of our services and our activities, we collect and process identity details and particulars, the financial and invoicing data of our clients and constituents, their staff, associates, agents and any other useful contact person.

Such processing is carried out in order to perform agreements with our clients, manage clients, accounts, visitor registration, manage litigation and social media, etc.

The legal bases are the performance of a contract, compliance with legal and regulatory obligations (such as the 30Bis declaration of work) and/or our legitimate interest.

5.2. Supplier and subcontractor data 

We collect and process identity details and particulars, financial and invoicing data, education, training courses, certifications, permits (residency, work permit etc.) of our suppliers and subcontractors, as well as any of their subcontractor(s),  employees associates, agents or any other useful contact persons.

Such processing is carried out to perform this agreement, to manage suppliers/subcontractors, accounts, litigation, communication, social media, business ethics, quality, the environment, health, safety and wellbeing.

The legal bases are the performance of a contract, compliance with legal and regulatory obligations (such as the mandatory electronic attendance registration, 30Bis declaration of work, attendance list and other obligations for public contracts, etc.) and/or our legitimate interest (such as direct prospecting). For the electronic attendance, the E-ID or LIMOSA number will be processed where required.

For the direct prospecting activities by e-mail (such as newsletters or invitations to events), authorization will always be required and may be withdrawn at all times.

5.3. Employee data

We process the personal data of our employees as part of our HR and payroll management. Given its specific nature, this processing is described in more detail in an Employee Data Protection Policy.

5.4. Other data

In addition to the client, supplier/subcontractor and employee data, we also process the personal data of other persons such as new clients/prospects, useful contacts in our sector, networking contacts, expert contacts, etc.

Such processing is carried out in the interest of our activities, direct prospecting and public relations.

The legal basis is our legitimate interests or, in certain cases, the performance of a contract.

6. Duration of processing 
  
Personal data are kept and processed by us for a required period depending on the purposes of the processing and the relationship (contractual or otherwise) between us.

Client and supplier or subcontractor data shall in any event be removed from our systems after ten years as of the termination of the contract, or after the end of the project, except as regards personal data that we are required to keep longer on the basis of specific legislation or in case of ongoing litigation for which the personal data are necessary.

7. Rights 
  

Pursuant to and in accordance with the conditions of the Belgian data protection legislation and the provisions of the general data protection regulation,  please be advised that you have the following rights:

  • Right to rectification: You have the right to obtain the rectification (correction) of inaccurate personal data concerning you, as well as complete personal data that are incomplete.
  • Right to be forgotten or right to restriction of processing: you have the right to ask us to erase personal data concerning you or to restrict the processing of such data in such circumstances and under such conditions as stipulated in the general data protection regulation. We may refuse to erase or restrict the processing of data which we require for the processing of salaries, fulfilment of a legal obligation, the performance of an employment contract or our legitimate interests, provided that such data are necessary for the purposes for which they were collected.
  • Right to data portability: You have the right to receive the personal data concerning you which you have provided us, in a structured, commonly used and machine-readable format. You have the right to transmit those data to another controller.  
  • Right to object: You have the right to object to the processing of your personal data on serious and legitimate grounds. You may not however object to the processing of data which we need to fulfil a legal obligation, perform an employment contract or in our legitimate interest, provided such data are necessary for the purposes for which they were collected.  
  • Right to withdraw your consent: If the processing of personal data is based on prior consent, you have the right to withdraw that consent. Such personal data shall be processed only if we have another legal basis.

Automated decision-making and profiling: We confirm that the treatment of personal data does not including profiling and that it will not be the subject of fully automated decision-making.

You can exercise the aforementioned rights by getting in touch with SPIE Belgium by sending an e-mail to privacy.be@spie.com or by sending a letter to  SPIE Belgium SA, Legal Department, 150-152 Rue des Deux Gares, 1070 Anderlecht.

We are making every effort to ensure a meticulous and legitimate processing of your personal data, in accordance with the applicable regulation. If you nonetheless feel that your rights have not been respected and that your concerns have gone unheeded in our company, you can lodge a complaint with the:

Data Protection Authority

35 Rue de la Presse, 1000 Brussels

Tel. 02 274 48 00

Fax. 02 274 48 35

E-mail: contact@apd-gba.be

You can also take legal action if you think you have suffered prejudice caused by the processing of your personal data.

8. Data transfers to third parties
  

Certain personal data of employees collected by the employer will be transferred and may be processed by third parties, in particular by our IT supplier, accountant, auditor, insurer, etc., by our clients as well as by the government (e.g. in the case of  a 30bis declaration of work, electronic attendance registration or the awarding of public contracts).

It is possible that one or more third parties are outside the European Economic Area (EEA). Nevertheless, personal data will be transmitted only to countries with an adequate level of protection.

Workers, managers and/or representatives of the aforementioned service providers or institutions as well as providers of specialized services designated by them, shall be required to comply with the confidential nature of your personal data and may use such data only for the purposes for which they were provided.

If necessary, personal data may be transmitted to other third parties. This can be done in case of a full or partial reorganization on our part, if our activities are transferred or if bankruptcy  is declared. It is also possible that personal data may have to be transferred because of an injunction or in order to fulfil a particular legal obligation. In such a case, we shall make every effort to inform you in advance of this communication to other third parties. You must nonetheless recognize and understand that this is not always technically or commercially feasible under certain circumstances or that legal restrictions may apply.

We shall under no circumstances sell your personal data nor place them at the disposal of direct prospecting agencies or similar service providers, except with your prior consent.


9. Technical and organizational measures 
  

We shall take technical and organizational measures to process the data at a sufficiently secure level and to protect personal data against destruction, loss, falsification, unauthorized access or notifications to third parties by mistake, as well as any unauthorized processing of said data.

Under no circumstances can SPIE Belgium SA be held liable for any direct or indirect damage caused by the erroneous or unlawful use of personal data by a third party.

10. Access by third parties 

For the processing of your personal data, we authorize access thereto to our employees, associates and agents. We guarantee a similar level of protection by imposing contractual obligations on said employees, associates and agents, similar to those described in the Data Protection Notice.

11. Do you have any questions? 
  

If you have any questions concerning the collection and processing of your personal data after reading this data protection notice, you can contact : SPIE Belgium SA, Legal Department, 150-152 Rue des Deux Gares, 1070 Anderlecht or by e-mail at: privacy.be@spie.com.

 

Anderlecht, 23 june 2022.

This information notice on personal data protection is valid in its current form until the next update.