PRIVACY POLICY ETUC – ACTION EUROPE
Version 13 June 2022
This is the Privacy Policy of Action Europe https://action-europe.org/privacy-policy , the petition platform operated by the European Trade Union Confederation (ETUC) (hereinafter “ETUC”, “us” or “we”). The ETUC is the voice of workers and represents 45 million members from 92 trade union organisations in 39 European countries, plus 10 European Trade Union Federations.
This Privacy Policy is intended to inform you about the personal data that the ETUC collects via Action Europe, to explain why we collect this personal data and how we deal with your personal data.
This Privacy Policy should be read together with our Cookie Policy.
TABLE OF Contents
1 When does this Privacy Policy apply?
2 Who is responsible for the processing of your personal data?
3 Which personal data do we process about you?
3.1 Information provided by you
3.2 Automatically obtained information
3.3 Information obtained from third parties
4 What is the legal ground for processing your personal data?
5 For which purposes do we process your personal data?
5.1 In order to animate a campaign online
5.2 In order to send communication of the ETUC
5.4 In order to answer your questions or other requests
5.5 For the technical and functional management of our websites
6 Who has access to your personal data?
7 Does the ETUC process your data outside the european economic area (“EEA”)?
8 How are your personal data protected?. 7
9 How long do we keep your personal data?
10 What are your rights and how can you exercise them?
10.4 Right to restriction of processing
10.5 Right to data portability
10.7 Right to object to the processing of your personal data for direct marketing purposes
10.8 Right not to be subject to profiling
10.9 Right to withdraw your consent at any time
10.10 Exercising the aforementioned rights
10.11 Competent supervisory authority
11 What about links to other websites and social media?
11.1 Social media pages of the ETUC
11.2 Social media sharing options
12 How are you informed of changes to this Privacy Policy?
13 Who can you contact in order to exercise your rights?
1 When does this Privacy Policy apply?
This Privacy Policy applies to the processing of your personal data in the context of the Action Europe petition platform of the ETUC.
2 Who is responsible for the processing of your personal data?
The ETUC is responsible for the processing of your personal data. This means that the ETUC determines for what purposes and with what means your personal data will be processed.
The ETUC has appointed a Data Protection Officer who will be your point of contact for any questions regarding the processing of your personal data. The contact details of the Data Protection Officer can be found under point 13 of this Privacy Policy.
3 Which personal data do we process about you?
We collect your personal data in three ways:
3.1 Information provided by you
In the first place, we receive your information when you share it with us. This is for example the case when:
- you sign a petition or a survey on Action Europe;
- you comment on a petition or a survey; when you provide us with your contact details; when you comment on the website of Action Europe, etc.
In these cases, you chose which information you provide us with. This information contains usually only your contact information such as your name, email address, country of residence, the language of the petition or survey you have signed and other petitions or surveys that you may have signed on Action Europe.
If you choose to provide this information, your union membership or your interest in union membership, roles that you fulfil (e.g. health and safety representation), details of campaigns you have supported and responses to campaign actions you have completed, the topics you are interested in (e.g. through preference centres), photos you upload to our site, and how you respond to the emails we send.
3.2 Automatically obtained information
When you browse the website of Action Europe, we receive data from cookie providers or social media by setting pixels (e.g. Facebook Pixel) about your activity on our website such as the webpages you visit, whether you opened an email or clicked on a link, etc. We can combine the automatically obtained information with the information provided by you to analyse your specific use of our website.
More information on the use of cookies by the ETUC can be found in our Cookie Policy.
3.3 Information obtained from third parties
In principle, we do not receive information through third parties. In the event that we do, it might be through our affiliates (National Trade Union Confederations and European Trade Union Federations, local trade unions (members) NGO’s or non-affiliated trade unions).
In this case, we receive the personal data you provided in the petition or the survey and your name, email address, and country of residence.
4 What is the legal ground for processing your personal data?
In general, the ETUC processes your personal data for various purposes, which are further explained below. Regarding the processing of your personal data, the ETUC relies on:
- your consent: your consent can be expressed e.g. by filling out a petition or a survey, by ticking a box to this effect during your navigation on our site, or via another positive action from which your consent is inferred, e.g. by choosing to contact us via email. In some cases (e.g. in case of personalised information) we will ask your explicit consent. You have the right to withdraw your consent for the future at all times.
- our legitimate interest: in some cases, the processing of your data may also be necessary to realise a legitimate interest of the ETUC (to organise trade union initiatives in light of the freedom of assembly and association (Art. 12 Charter of Fundamental Rights of the EU)) . We have taken actions to make sure that your interests or your fundamental rights and freedoms outweigh our legitimate interest.
For the processing of special data (such as trade union membership and political opinions), we rely in addition on:
- your explicit consent: you express this explicit consent in the petition or survey you sign where we obtain your personal data. You have the right to withdraw your consent for the future at all times.
- the processing is carried out in the course of our legitimate activities with appropriate safeguards as a non-profit organisation with a trade union aim and to the extent that the processing relates to the members, former members or to persons with whom we have regular contact. The processing happens in connection with our social purpose, respect for human and trade union rights (the freedom of assembly and association, Art. 12 Charter of Fundamental Rights of the EU). Your personal data is not transferred outside our organisation without your consent.
- When you have made your personal data manifestly public: by providing us this data yourself in a petition or survey.
5 For which purposes do we process your personal data?
The ETUC processes your personal data for the purposes listed below.
5.1 In order to animate a campaign online
In order to give a voice to workers and their families in Europe in issues of politics or business/industry, we have set up Action Europe. If you sign a petition or survey, you consent to provide us your personal data. We process your personal data to carry out our fundamental task of trade union initiatives (cf. the freedom of assembly and association, Art. 12 Charter of Fundamental Rights of the EU) at the European level as part of the process of European integration. We may contact you to stay informed if you provided your consent. This also allows us to communicate with you on the petition or survey you signed.
The processing then concerns your contact information such as your name, email address and country of residence, the language of the petition or survey you have signed and other petitions that you may have signed on Action Europe. This data might also include questions regarding your trade union membership or your interest in trade union membership.
This processing is based on your consent and on our legitimate interest. Your consent is provided by your participation in the petition or survey and the completion of your email address. To the extent that special categories of data are involved (e.g. trade union membership or political opinions), we rely in addition on your explicit consent. You have the right to withdraw your consent at any time (see point 10).
5.2 In order to send communication of the ETUC
General communication
We store data on preferences that you submit to us (through e.g. preference centres), or from campaign actions you take with us (e.g. to thank you for signing the petition or survey and to invite you to share it on social media channels), to help us send you information that more closely matches your interests, or to follow up on issues you have been involved in (such as new information, campaigns and petitions or survey regarding our organisation, or to keep you up to date on the petitions or surveys you have signed). We can send you communication via email, text message, phone, social media (including but not limited to Facebook, LinkedIn, Twitter), our websites and affiliated websites or SMS. For this purpose, we can process personal data such as your name, your address, your email address, your phone number, your country of residence, your topics of interest, language of the petitions or surveys you signed and other petitions or surveys that you may have signed on Action Europe.
We can send you communication if you have explicitly consented to it by ticking the relevant boxes on the forms we use to collect your data. In this case, you are free to choose to provide us with your personal data for communication purposes. To the extent that special categories of data are involved (e.g. trade union membership), we rely in addition on your explicit consent.
You have the right to withdraw your consent for the processing of your personal data for communication purposes at any time (see point 10).
Personalised communication
Moreover, we may process your personal data to provide information regarding the petitions or surveys you have signed, the surveys you have filled in, and the topics you have expressed your interest in. For instance, to invite you to attend a physical or online meeting, to have a phone call, to invite you to join a specific Facebook group on the subject of your interest, to ask you if you like to be put in contact with a union organiser, or to contact you for fundraising donations. For this purpose, we process personal data such as your name, your email address, your phone number and your country of residence, language of the petitions or surveys you signed and other petitions or surveys that you may have signed on Action Europe.
We can automatically send emails to policymakers at local, regional, national or EU level or to company management or business/industry organisations to ask for something, for example to take decisions. For this purpose, we process personal data such as your name, your email address, your country of residence, language of the petitions or surveys you signed and other petitions or surveys that you may have signed on Action Europe.
5.3 In order to gain insights to carry our task of trade union initiatives and foster the freedom of assembly and association
The ETUC can process your personal data for analytic and statistical purposes in order to gain insights that allows us to carry out our fundamental task of trade union initiatives (cf. the freedom of assembly and association, Art. 12 Charter of Fundamental Rights of the EU) at the European level as part of the process of European integration.
Statistical purposes mean any operation of the collection and processing of personal data necessary for statistical surveys or for the production of statistical results. We can carry out sentiment analysis in surveys in order to better inform the ETUC on attitudes of signatories of petitions or surveys on this platform. The ETUC makes use of different analytic tools in order to connect personal data and retrieve insights from different data sources.
For this purpose, we can process personal data such as your name, email address, country of residence or other personal information you have provided us.
We can share these insights with our affiliates (National Trade Union Confederations and European Trade Union Federations, local trade unions (members), NGO’s or non-affiliated trade unions) in order to advance our fundamental task of trade union initiatives.
Depending on the individual case, these data are processed on the basis of your consent and on the ETUC’s legitimate interest to evaluate and improve our communication campaigns, to gain insights in our sales reports and to visualise our e-commerce data. When the data includes sensitive data (e.g. trade union membership), we rely on your explicit consent. You have the right to withdraw your consent at any time (see point 10).
The result of the processing for statistical purposes are aggregate data. We do not use the aggregate data or your personal data in support of measures or decisions with regard to you.
5.4 In order to answer your questions or other requests
We process your personal data in order to answer your questions or requests (for example when you request more information on a petition or survey).
For this purpose, we can process data such as your name, your email address, your country of residence, language of the petitions or surveys you signed, other petitions or surveys that you may have signed on Action Europe, your correspondence with the ETUC, and if provided, your phone number.
These data are processed on the basis of the ETUC’s legitimate interest to handle your questions and requests in the best possible way and to communicate with you.
5.5 For the technical and functional management of our websites
We process personal data obtained through cookies and other technologies for the technical and functional management of our websites, in order to personalise the websites and to ensure that the websites are easy to use. By using your data, we can check how our website is used and we can improve its content and layout. These data also allow us to adequately secure our website.
For this purpose, we can process data such as your IP address, the pages you visit, the browser you use, the websites you visited earlier, geographical data such as your location, your preferred language and the time and duration of your visit.
The processing of these data is based on your unambiguous consent (captured via our cookie banner) or based on the ETUC’s legitimate interest in providing a well-functioning and secure website and in providing pages with content relevant to you. You have the right to withdraw your consent at any time (see point 10).
You can find more information about how we use cookies in our Cookie Policy.
6 Who has access to your personal data?
The ETUC is selective in the parties to whom it discloses your personal data and chooses them carefully. In all cases, we will ensure that sufficient safeguards for the protection and confidentiality of your data are in place.
In the following cases, we share your personal data with third parties:
- Our affiliates (National Trade Union Confederations and European Trade Union Federations, local trade unions (members), NGO’s or non-affiliated trade unions) when they organise a petition or survey, alone or together with the ETUC, we can share your contact details and petition or survey details.
- Processors who provide the platform and its technical and functional operation (e.g. the Impact Stack petition platform from More Onion), web hosting companies, mailing vendors, software providers, analytics providers, tracking companies, …. The ETUC concludes a processing agreement with the parties that have access to personal data for the performance of their services.
- IT service providers that provide technical support.
- Attorneys and external advisors: in certain cases, the ETUC may transfer your personal data to attorneys and external advisors if this is necessary to give us advice or to defend our rights.
- Social media: social media may have access to the information collected through cookies and other technologies (possibly via the plug-ins embedded on the ETUC websites).
- Visitors of the Action Europe website: you may, of course, choose to publish or share parts of your information with others by using our message boards, comment functions, your profile page and other sharing tools. In that case, visitors of Action Europe can see and read the personal data you have published. You have control of any data you choose to publish or share using these platforms.
- Policymakers at local, regional, national or EU level or company management or business/industry organisations: we may provide these parties with a list of signatories to achieve the objective of the petition or survey and demonstrate the support.
7 Does the ETUC process your data outside the european economic area (“EEA”)?
In principle your personal data will not be transferred to sub-processors located outside the European Economic Area. In the rare event that this would be the case, the ETUC is committed to ensuring an adequate and sufficient level of protection for your data, in particular by making sure that we can rely on a an adequacy decision under Article 45 of General Data Protection Regulation (“GDPR”), by concluding standard contractual clauses under Article 46.2 GDPR or via any other appropriate safeguards as provided for by Chapter V GDPR.
If you have any questions or would like more information about the possible transfer of your personal data outside the EEA, you can send a dated and signed request to the ETUC by email or by mail. You can find our contact details in point 13.
8 How are your personal data protected?
The ETUC strives to protect your personal data as good as possible by means of administrative, technical and organisational measures. To this end, the ETUC has developed several procedures which are implemented by our employees.
The ETUC furthermore has committed to ensure that the service providers that process personal data on behalf of the ETUC (e.g. More Onion) also implement sufficient technical and organisational measures.
9 How long do we keep your personal data?
The ETUC will retain your personal data in a petition or survey for 2 years or for the period necessary to fulfil the purposes outlined in this Privacy Policy.
Longer retention periods may be required in case of a dispute.
10 What are your rights and how can you exercise them?
Under the GDPR, you have a number of rights with regard to your personal data. Some of these rights have a very specific scope or are subject to special conditions or exceptions.
10.1 Right of access
This means for example that you can ask us whether we process your personal data and for what purposes we do this. For more information, please consult Article 15 GDPR.
10.2 Right to rectification
You also have a right to obtain the rectification of inaccurate personal data. For more information, please consult Article 16 GDPR.
10.3 Right to erasure
In some cases, you can request us to erase your personal data for example when personal data is no longer required for the purposes for which we have collected it, when the personal data is processed based upon your consent and you withdraw your consent, etc.
In some exceptional cases, the ETUC is not obliged to grant your request to erase your personal data. For more information, please consult Article 17 GDPR.
10.4 Right to restriction of processing
You may request a restriction of your personal data for example if you dispute the accuracy of your personal data, if the processing activity is unlawful, etc. A restriction of the processing means that we may only store your data temporarily, except in case you nevertheless consent to the processing of your data, in the context of legal proceedings or in the public interest. A restriction can be terminated afterwards. For more information, please consult Article 18 GDPR.
10.5 Right to data portability
If we process your personal data based upon your consent you can ask us to transfer your data to yourself or to another controller (if this is technically possible). In exceptional cases, the ETUC is not obliged to follow up on your request. For more information, please consult Article 20 GDPR.
10.6 Right to object
You can inform us of the particular reasons why you wish to object to the particular processing activity based upon the ETUC’s legitimate interest. If these particular reasons outweigh our legitimate interests, we will terminate the processing activity. The ETUC cannot follow up on your request when we process your personal data for the purposes of a legal claim. For more information, please consult Article 21 GDPR.
10.7 Right to object to the processing of your personal data for direct marketing purposes
If we process your personal data for direct marketing purposes, you can always request us to stop processing your personal data without you having to give up a special reason. This right includes the right to object to profiling to the extent that the profiling is related to such direct marketing. For more information, please consult Article 21 GDPR.
10.8 Right not to be subject to profiling
The ETUC can process your personal data for profiling purposes as explained in point 5.3 of this Privacy Policy). As this profiling only takes places for direct marketing purposes, you have the right to object to profiling for our direct marketing at any time, without you having to give up a special reason (as explained in point 10.7). For more information, please consult Article 21 GDPR.
10.9 Right to withdraw your consent at any time
If the processing of your data is based on your consent, you also have the right to withdraw your consent at any time, without this affecting the legitimacy of the processing done prior to the withdrawal of your consent.
10.10 Exercising the aforementioned rights
Exercising the abovementioned rights can easily be done in different ways, such as by email or by mail. For privacy and safety reasons, we may request proof of your identity. You can find our contact details in point 13.
10.11 Competent supervisory authority
In accordance with Article 77 GDPR, you have the right to lodge a complaint with the supervisory authority of your habitual residence, your place of work or the place of an alleged infringement of the GDPR. The Belgian Data Protection Authority is the supervisory authority for the headquarters of the ETUC located in Belgium.
The Data Protection Authority can be contacted at Drukpersstraat 35, 1000 Brussels (by telephone: +32 (0)2 274 48 00; email address contact@apd-gba.be).
11 What about links to other websites and social media?
The Action Europe website of the ETUC can contain references (for example via hyperlinks, social plug-ins, links to social media operators) to other websites, which are offered by other companies or by social media, or to our own website. The ETUC always advises you to check the privacy policies of those websites.
You can access the Privacy Policy of our website www.etuc.org/en on this link.
11.1 Social media pages of the ETUC
The ETUC has pages on LinkedIn, Twitter, Facebook, YouTube, Flickr and Instagram. When you visit these pages, your data will be transmitted to the operator of the respective social network through the use of cookies. Social networks may receive information such as which websites you have currently and previously visited and your IP address. When you visit these pages, it is possible that we receive aggregated data from the respective social network in the form of statistics about how our pages are viewed by social media users.
For the scope and purpose of data collection as well as the further processing and use of data by social networks and information on rights and settings to protect your privacy, please refer to the privacy policies of these social networks (available here: LinkedIn, Twitter, Facebook, YouTube, Flickr, and Instagram).
More information on the use of cookies by the ETUC can be found in our Cookie Policy.
11.2 Social media sharing options
Our website allows you to share content with Twitter, Facebook and email. When using these social plugin functions (e.g. “share” button, …), information about your usage is transmitted directly from your browser to the corresponding social network. If you are already registered with a social network while visiting our website, the operator of that social network may be able to assign the visit to your personal account through the social plugins. If you are not yet a member of a social network, it is still possible for the social networks to receive and store your IP address and information about the browser and operating system you are using through the social plugins.
If you share content from our website on the social media page directly, your personal data will be visible for the visitors of these social media. For the scope and purpose of data collection as well as the further processing and use of data by social networks and information on rights and settings to protect your privacy, please refer to the privacy policies of these social networks (available here: Facebook and Twitter).
More information on the use of cookies by the ETUC can be found in our Cookie Policy.
12 How are you informed of changes to this Privacy Policy
This version of the Privacy Policy was last modified on 13 June 2022.
We strive to provide you with the best service. Therefore, this Privacy Policy can be modified. We thus advise you to check this Privacy Policy regularly on the Action Europe website. Any major changes to our Privacy Policy in the future will be posted to the Action Europe website and, where appropriate, sent to you by email notification.
13 Who can you contact in order to exercise your rights?
If you have any further questions or complaints about the processing of your personal data, about Action Europe, or about this Privacy Policy you can always contact our data protection officer:
- By email at privacy@etuc.org;
- By mail to:
Data Protection Officer
European Trade Union Confederation (ETUC)
Boulevard du Roi Albert II 5
1210 Brussels
Belgium