Date: 5 August 2020
International and national laws and regulations, including the EU General Data Protection Regulation and other data protection laws worldwide, set out rules on the processing and movement of Personal Data. At the same time, as an intergovernmental organisation, the OIE is subject to international public law, entrusted with a number of privileges and immunities necessary for its functions. Accordingly, the OIE has decided to self-regulate the protection of your privacy and your Personal Data to ensure it processes your data in accordance with generally accepted standards.
“Personal Data” means personally identifiable information about an individual, such as a name, address, email address, phone number, or other identifier that permits direct or indirect identification of a specific individual.
2. What information do we collect?
We make sure to collect only data that is necessary for the purpose for which it is processed. When we collect your data through a form, the mandatory nature of the information is indicated by the presence of an asterisk or by any other equivalent method. Failure to provide this information will make it impossible for us to process your data for the purpose intended.
Data not marked with an asterisk or equivalent is optional. It enables us to improve our communications or services to you, but you are not obligated to provide it. Failure to provide such data will not result in the impossibility of processing your request.
We may collect and process the following data:
2.1 Website Users
We process information about Website Users directly from you and automatically through your use of our Websites.
2.1.1 Personal Data we collect automatically or directly from Website Users
You may also choose to give us Personal Data in certain instances, such as when placing an order on the OIE online bookshop, subscribing to an OIE newsletter, responding to our emails, enter contests or when using certain advanced features which require registration.
In addition to the “unsubscribe” link generally available, you may free of charge and at any time opt-out of receiving newsletters or other communications from the OIE by sending an e-mail to the focal point for that website.
Certain Websites may enable you, by creating an account, to communicate with others and to post information accessible by others. You should be aware that when you choose to use these features, your information may be available to other users and the OIE has no control over the use of your Personal Data by these users.
When you choose to register on a Website, the Personal Data we collect may include, without limitation:
- your name;
- your email address;
- your country of residence.
By browsing on our Websites, you may find links to third-party websites for which the OIE is not responsible in terms of content nor privacy policies.
2.2 Concerned Individuals of Partners
In the context of pursuing our mandate, the Personal Data we may process related to you as a concerned individual of Partners:
- contact information, such as full name, postal work address, work telephone number, work mobile phone number, work email address, and job title;
- data necessary for processing payments and fraud prevention;
- further information necessarily processed in a project or contractual relationship with us or voluntarily provided by the concerned individuals of the Partner;
- Personal Data collected from publicly available resources; and
- other Personal Data, if such information is required by us for due diligence or compliance screenings of Partner in line with internal rules.
In the context of an application with us, the Personal Data we may process related to you as an Applicant includes:
- information such as name, contact details, gender, citizenship;
- additional information you may volunteer to further provide information on your application, such as work competencies, work experience, education and certifications, references, cover letter, job preferences, and related uploaded or transmitted documents.
3. How we use Personal Data and legal basis for the processing
We may collect and retain Personal Data during the course of our interactions in order to pursue our mandate. We may collect Personal Data that you choose to provide us via our websites, surveys, emails, correspondence or personal meetings or phone calls between yourself and OIE’s staff or agents.
Your data is collected for specified, explicit and legitimate purposes and no further processed in a manner that is incompatible with those purposes.
We hold, process and transfer your Personal Data but solely for legitimate purposes, and it is only disclosed on a need-to-know basis to those who are authorised to use it for these purposes.
We process the Personal Data listed above for the following lawful purposes:
- As required to establish and perform a contractual relationship, to maintain or terminate it and to enable us to manage your account and any services applicable to you;
- As required by us to carry out our mandate and pursue our legitimate interests, and where our interests are not overridden by your data protection rights;
- As required to comply with our legal obligations which require processing according to the rules to which the data controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the data controller;
- Where you have given consent.
We also reserve the right to process your Personal Data that we believe, in good faith, is appropriate or necessary to guard against liability or investigate and defend ourselves against any third-party claims or allegations.
3.1 Website Users
We use the Personal Data of Website Users for the following purposes:
- as required by us to pursue our legitimate interests in ensuring the security of the platform we manage, we collect and process your Personal Data to ensure the proper operation and security of our Websites;
- the processing of your data for the purpose of sending you our newsletters is carried out on the basis of your consent. This consent is shown by ticking a box or filling in the fields enabling the service to be provided;
- the processing of your data for the purpose of purchasing our products is based on the execution of a contract or contractual measures to which you are party;
- to comply with applicable obligations or internal rules, including, but not limited to, use in connection with legal claims, compliance, investigative purposes (including disclosure of such information in connection with legal process or litigation).
3.2 Concerned Individuals of Partners
- We process Personal Data of concerned individuals of Partners in the context of a work relationship with Partners for the following purposes:
- to establish and perform a contract with you, a request for quotation or a purchase order purposes based on the execution of a contract or contractual arrangements you are party to. This may include performing transactions and orders verifying your identity, communicating with you processing payments, performing accounting, auditing, billing and arranging the delivery or other provision of products, goods or services;
- to pursue our legitimate interests in managing our relationship with you, in particular to respond to any comments or inquiries you may send us;
- to comply with our legal obligations (such as record keeping obligations) which require processing according to the rules to which we are subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in us, due diligence and compliance obligations (e.g. to prevent fraud), and to protect the OIE’s legitimate interests and legal rights, including, but not limited to, use in connection with legal claims, compliance, especially investigative purposes (including disclosure of such information in connection with a legal process or litigation).
We process Personal Data of Applicants in the context of recruitment for the purpose of application management based on the execution of a contract or pre-contractual arrangements to which you are party, which includes the following:
- as required exclusively to administer, process and evaluate your application or to assess your suitability for available roles based on your profile;
- if you provide the details of a reference or any other third party e.g. educational institution as part of your application, this authorises us to contact the said person or organisation to validate any information provided and related to the relevant work experience and qualifications;
- during the recruitment process we may ask you to provide us with additional information or request additional consent allowing us to conduct pre-employment checks to further assess your qualifications and suitability for the role you applied for or for other roles.
4. How Long we Retain Personal Data of Data Subjects
In principle, we will keep Personal Data for as long as it is necessary for the relationship with you or otherwise required to meet our legal obligations. Some data may be archived, for example to manage ongoing complaints and disputes as well as to meet our legal obligations.
If we process Personal Data based on consent, we will delete this Personal Data upon withdrawal of the consent or at the end of the retention period set regarding the purpose of the processing.
Regarding Website Users, we retain your data for 3 years from the last contact we had with you in the event of a request for information from you or the sending of our newsletters. If you are a customer, we will retain your data 3 years from the end of our business relationship. We will retain your data for 2 years from the last contact we had with you if you are an Applicant.
Before the expiry of these periods, we may contact you again to find out whether you agree to a longer retention of your data. In that case, the above-mentioned periods will start again. The OIE also provides for specific retention periods in certain cases.
The data necessary for registration on our Websites will be kept until your account is deleted at your initiative or in the event of inactivity of your account, 2 years from the last action you took in the absence of a response from you regarding the possibility of deletion of your account.
Once the purpose for which the Personal Data was initially collected is achieved and the retention period ended, we will delete or anonymise it in a secure manner without unreasonable delay.
5. To whom may we disclose Data Subjects’ information?
- Service Providers: Personal Data may also be shared with third party service providers, which will process it on behalf of us for the purposes above. Such third parties include, but are not limited to, payroll service providers, IT service providers, data hosting providers, travel agencies, banks, training providers, auditors and professional advisers, insurers, public bodies, website management providers.
- Member Countries and Resource Partners: Personal Data may be shared with member countries and/or resource partners only if it is necessary for the purposes above, or if required for the legal protection of our legitimate interests.
- Government Authorities/ Law Enforcement Officials: Personal Data may be shared with government authorities and/or law enforcement officials only if it is necessary for the purposes above, or if required for the legal protection of our legitimate interests.
- Other Unaffiliated Third Parties. We may disclose your Personal Data, only if it is necessary for the purposes above, or if required for the legal protection of our legitimate interests.
- Google, for the statistical analysis solution of the Websites.
- Other users on our Websites when you choose to use features allowing other users to have access to your information.
Other than the cases where we may disclose your data to third parties where such disclosure is required or as per legal obligations which require processing according to the rules to which we are subject, or for important reasons of public interest, or where it is necessary to protect and defend our rights, your data will not be transferred or made accessible without your prior consent to any third party for other purposes than the ones aforementioned.
6. Transborder storage and transfer of Data Subjects’ Personal Data
The OIE is committed to maintaining the security of data, including Personal Data, regardless of whether it is inside or outside the EU. We may transfer Personal Data to countries outside the European Union. In such a case, we ensure that the transfer is carried out in accordance with the appropriate safeguards which ensure an adequate a sufficient level of protection for the privacy of Data Subjects.
7. Security of Personal Data
We consider the confidentiality of Personal Data collected from you to be of utmost importance. To prevent unauthorised access, disclosure, interference or misuse, we use reasonable efforts to safeguard the security and confidentiality of your Personal Data.
Browsing on our Websites involves the deposit of cookies. Cookies are small text files stored on your device, grouping together a certain amount of data about your navigation (e.g. date, time and number of visits, source of arrival, preferences).
- Ensure the proper functioning of the Websites
- Anonymously analyse page traffic (number of visits, visitor activity, return frequencies) and the performance of the website
- To this end, other cookies may be placed on your terminal by Google. These cookies are governed by Google’s own personal data protection policy, which can be accessed by clicking on the following link: https://policies.google.com/privacy?hl=fr&gl=fr
- To offer you personalised advertisements
- Cookies are kept for a duration that is proportionate to their purpose and no longer than 13 months. This period is not extended by your new visits.
Generally, as soon as you arrive on our Websites, an information banner informs you that we use this technology, their purposes and allows you to accept or refuse the deposit of cookies on your terminal.
8.1 Setting cookies
The deletion of functional cookies, which are necessary for the provision of content by us, may prevent you from accessing certain content on the Websites.
The OIE declines all responsibility for the consequences related to the degraded functioning of its Websites resulting from the impossibility of recording or consulting the cookies necessary for the functioning of the Websites, and which you would have refused to deposit or required to delete.
You can nevertheless generally configure your choice of cookies from the cookie banner as soon as you connect to our Website by clicking on the “cookie settings” button.
– Choices offered by your browser software : You can configure your browser software so that cookies are saved on your device or, on the contrary, that they are rejected, either systematically or according to their transmitter. You can also configure your browser to accept or reject cookies before a cookie is likely to be stored on your device.
– How do you implement your choices, depending on the browser you are using? Cookie management differs depending on the configuration of each browser. For more details, click on the links below.
- For the Internet Explorer™: http://windows.microsoft.com/fr-FR/windows-vista/Block-or-allow-cookies
- For Safari™: https://support.apple.com/kb/ph21411?locale=fr_CA
- For Google Chrome™: http://support.google.com/chrome/bin/answer.py?hl=fr&hlrm=en&answer=95647
- For Firefox™: https://support.mozilla.org/fr/kb/activer-desactiver-cookies-preferences
- For Opera™: http://help.opera.com/Windows/10.20/fr/cookies.html
9. Data Subject´s Rights in Relation to their Personal Data
You will generally have the following rights:
a) Right of access: You can request information from us, in each case at reasonable intervals and without excessive delay or expense, as to whether and how we process your Personal Data and request that we give you access to your Personal Data or send you a copy of it.
b) Right to rectification: If you believe that the Personal Data we hold about you is incorrect or incomplete, you can request us, free of charge and without excessive delay, to correct it or complete it.
c) Right to object: You may also have the right to object to the processing of your Personal Data based on our legitimate interests unless we have legitimate grounds which override your data protection interests.
d) Withdrawal of consent: If we process your Personal Data based on your consent, you have the right to withdraw your consent at any time. You can withdraw your consent by following the instructions in the relevant communication. Your withdrawal will not affect the lawfulness of the processing carried out before you withdrew your consent.
e) Right to erasure: You can request the erasure of your Personal Data unless we are required to retain it.
f) Right to data portability: You also have the right to request that we transfer your Personal Data to another party. This data will be communicated in a structured, commonly used and machine readable format where available, where technically feasible and to the extent you provide adequate transmission information and cover any costs in advance.
Paragraphs b), c) and e) above shall not apply where processing is necessary for:
- scientific, historical research, statistical or archiving purposes, for the delivery of the OIE’s mandate and programme of work, in so far as the rights referred to in paragraphs b), c) and e) are likely to render impossible or seriously impair the achievement of the objectives of that processing;
- reasons of public interest in the area of public health;
- for the establishment, exercise or defence of legal claims.
You also have the right to issue instructions regarding the fate of your Personal Data after your death.
To exercise your rights, you may contact us at [email protected] or by post at the following address: OIE, 12 rue de Prony, 75017 Paris, France, to the Legal Unit- DPO service.
With regard to these rights some restrictions apply. For example, we cannot delete Personal Data if we are obliged to store it for legal reasons, according to the rules which apply to us or for the performance of a task carried out in the public interest. In addition, information about and access to Personal Data may be denied if Personal Data about another person would be disclosed with the provision of the information or in case of the overriding operational needs and priorities of the OIE in pursuing its mandate or work programme, or if there are grounds for believing that the request is manifestly abusive or fraudulent.
12. Data Controller and Contacting Us
Generally, the data controller for the Personal Data of Data Subjects is the OIE office you have the relationship with.
World Organisation for Animal Health
Legal Affairs Unit – DPO service
12, rue de Prony 75017 Paris, France
The DPO will investigate the complaint within three months of receipt. It may extend the time-limit if it considers the complaint to rest on complicated facts or legal considerations and give prior notice to the complainant. When investigating claims, the DPO may invite the individuals concerned to express written views on the claims and the relevant facts and to provide evidence. After reviewing the claim, the evidence and the written views, the DPO will transmit its reasoned, binding and final conclusions and any recommendations of corrective measures to the Director General. The Director General will take a decision in accordance with the conclusions of the DPO and notify it to the claimant.