LUCA School of Arts Privacy Statement
LUCA requests and processes a lot of personal data in order to carry out its assignments (teaching, research and services, employer, etc.) correctly. This includes the personal data of students, alumni, staff members andresearch participants.
LUCA wants to respect your privacy always and everywhere, which is why we want to inform you in a transparent way about which personal data we collect and process, for which objective and for how long we keep them, what your rights are and how you can exercise them. Of course, LUCA takes the necessary organisational and technical measures for the protection and security of your personal data.
Who is the data controller?
The LUCA School of Arts non-profit association, with its registered office at Rue des Palais 70, B-1030 Brussels, is the data controller for the processing of your personal data. Personal data must be processed in accordance with the provisions of the General Data Protection Regulation (GDPR).
LUCA School of Arts has appointed a data protection contact person:
verantwoordelijkegdpr@luca-arts.be. This expert ensures that LUCA correctly handles the large amount of data concerning its students, alumni and staff members.
From which categories of persons is the data processed?
Students
The processing of student data is performed in a transparent manner. Students will be informed about the use of their data at the time of their enrolment and asked for their consent where necessary.
There are several categories of processing.
Such as, processing in the context of student and education administration; in the context of quality assurance and finally in the context of the provision of academic advising and student services.
LUCA processes student data on a legal and contractual basis or on a basis of consent. This involves processing in the context of the programmes and curricula offered by LUCA as stipulated in the Higher Education Code. This includes registering students, organising teaching activities, keeping track of examination results, issuing degrees, stipulating internal and external registrations, information flows and communication.
The following types of data are processed:
identification data, national registration number, financial data, personal characteristics, data concerning health, migration background (nationality), programmes and training, living habits, family composition, leisure activities, housing characteristics, employment.
The personal data of students is managed in a centrally managed student administration office (SAP). The IT service of LUCA and the KU Leuven (the supplier of SAP) ensure appropriate security for the SAP environment. Strict authorisation management determines who is allowed to access and/or modify which data. This is done by assigning the roles and/or tasks according to the functions of the staff members processing the student data.
Data sharing
Where parents, relatives or other third parties are concerned, no student data will be shared unless they can prove that they represent the student legally or that the student agrees explicitly to the communication of certain data.
At the request of the police and the courts, LUCA may disclose the personal data of students.
LUCA processes also the external data provided by the Flemish government for the monitoring of student careers.
The personal data of students will be used by LUCA for no longer than necessary solely for the purpose of processing and will not be kept any longer than necessary.
Prospective students
We process the personal data of prospective students who register via our website, including for online registration, registration for an artistic entrance test or a Master's Degree Assessment. Personal data is also processed from students who register via the Study Information Days (SID-In).
This includes data such as: identification data, contact details, personal characteristics, data concerning studies, programmes and degrees.
Alumni
LUCA processes the personal data of former students as part of its alumni activities. There are two considerations in this regard. On the one hand, LUCA's desire for performing alumni processing and, on the other, the privacy of the former students.
The personal data of alumni is kept in a database.
Without the consent of the alumni, their data cannot be passed on to third parties.
General personal data (address details, programmes, degrees obtained) are transferred from the student database to the alumni database. By virtue of any legislation and for the purpose of the necessary awarding of certificates to the authorities, these may be kept by LUCA.
In addition to general personal data, data may also be maintained which the alumnus, as a student, has made available himself/herself.
Staff
LUCA's Personnel Department processes the staff records on the basis of the employment, appointment or nomination contract and on the basis of any legal obligations, legitimate interest or explicit consent of the staff member.
The processing operations are carried out for the purposes of implementing the employment / appointment / nomination agreement for:
• drawing up and maintaining an individual administrative staff record: personal details, contact details, leave schemes, seniority, job description, pay scale, evaluations, holiday arrangements, absences, bonuses, pay deductions, car information, insurance policies, commuting subscriptions, etc.
• payroll administration: the data necessary for carrying out payroll processing and the payment of wages by LUCA or by the Flemish Government
The following types of data are processed:
identification data, national registration number, financial data, personal characteristics, family composition, data concerning programmes and degrees, career data, absences.
The staff records are managed on a centrally managed personnel administration software platform (PERSONA). The IT service and platform provider ensure the appropriate security for the PERSONA environment.
Sharing of data
Only in connection with a legal obligation or when LUCA has a legitimate interest will personal information be disclosed. In doing so, permission is always sought from the staff members concerned.
Within the framework of the execution of the contract with the staff member, LUCA will exchange the necessary data with the competent government departments, social secretariats and an occupational health service.
After the termination of employment, some data will be kept which can be used, for example, for the certification of their employment.
Applicants
LUCA processes the data provided by the applicant with a view to conducting a proper selection procedure.
Access to the details of the applicants will be available to the relevant staff members of the Human Resources Department, supplemented by the members of the selection committee.
Personal data may be shared with third parties in the following cases:
• for taking psycho-technical tests, among other things through registration in the testing system.
• for participation in an assessment centre
Participants in research
The processing of the participants' data will vary depending on each specific research project. Wherever possible, LUCA tries to process this data further in anonymised or pseudonymised form.
If research data is collected directly from the participant, the participant will be informed at the start of the research about which data is collected, for which objective and on which basis, for how long and whether the data will be shared with third parties.
Suppliers
Some services (for example, Finance and Communications) also keep personal data from suppliers. This mainly involves the identification data and financial information necessary for proper administration, the follow-up invoicing and the payment for the goods or services provided. This personal data is kept for as long as required by law or as long as the data is needed for the above objectives.
On which legal grounds can LUCA process your personal data?
In accordance with the General Data Protection Regulation, LUCA may process your personal data in the following instances:
• legal obligation
• agreement
• consent
• legitimate interest
• vital interest
• public interest
In most cases, we process some necessary personal data in order to be able to execute the agreement between you and the university college (for example: keeping payment details regarding the enrolment, the academic progress file, the staff record and the payment of wages).
Moreover, in many cases we process data because it is required by law. For instance, we are obliged to pass on student data to the Higher Education Database (DHO) because of the legal regulations related to monitoring academic progress. Another example is the Dimona tax return for staff members when taking up or renewing employment.
Moreover, some processing requires explicit consent. This is the case, for example, when we process data concerning the health of students in order to obtain adapted facilities due to special needs.
Use of visual material
Photographs and video recordings may be taken during activities within the university college where persons (students, staff, third parties, etc.) could be recognised. This material may be used for educational purposes and for internal or external communication and publications (such as brochures, promotional material, website and press releases). When publishing this visual material externally, the privacy interests of the people depicted will be weighed against the interest of LUCA in publishing the visual material.
Which measures does LUCA take in order to protect your personal data?
LUCA takes both organisational and technical measures in order to ensure maximum privacy protection against any unauthorised access, use, loss or theft of personal data.
Organisational measures:
Organisational measures are interventions which may restrict physical access to data (carriers), this applies both digitally and on paper.
LUCA strives to limit the number of employees who have access to personal data to those who actually needthis information to adequately fulfill their assignment.
Technical measures:
Technical measures are specifically aimed at the protection and security of digitally stored and transmitted data, such as:
• centralised platform and service management
• password policy
• multi-factor authentication
• encryption
• pseudonymising and anonymising
• firewall and anti-virus
Exercising your data protection rights
The right to inspection
You have the right to know whether or not LUCA is processing personal data about you. And you also have a right to inspection.
The right to correction
If your personal data is incorrect, you have the right to have it corrected.
Students may change some of the details in their student records themselves by using KU Loket, such as their calling name, address and contact details, account number.
The right to the erasure of data ("the right to be forgotten")
You have the right to have your personal data erased in the following cases:
• when your data is no longer needed for the purposes for which it was collected or processed;
• when you withdraw your consent and no other legal basis exists for the processing;
• when you object to the processing and no compelling legitimate grounds for the processing exist;
• when your data was unlawfully processed;
• when your data must be deleted due to a legal obligation.
The right to withdraw consent
You may withdraw your original consent at any time. This cannot be done retroactively.
The right to the restriction of processing
You have the right to restrict the processing of your data:
• during the period when LUCA needs to:
o check the accuracy of your data
• assess the existence of the grounds for the erasure of personal data. When the data processing is unlawfuland you wish to restrict processing instead of erasing the personal data
The right to object
You have the right to object to the processing of your data at any time based on any grounds whatsoever.
The right to data portability
The right to data portability should allow you to retrieve and reuse your personal data for other services. You have the right to retrieve the data, which you have provided to LUCA, in a structured, user-friendly and digitally readable form.
You have the right to transfer that data to another service provider if:
• the processing takes place on the basis of consent or an agreement;
• it involves automated processing (no paper documents);
• you have provided the personal data yourself.
The right to complain
You have the right to lodge a complaint regarding the processing of your data with the Belgian Data Protection Authority (DPA).
How can you exercise your rights?
In order to exercise your rights, you can submit a request using this application form.
This application form does not allow the viewing of individual files (for example, selection files at the Personnel Department, an examination for a student).
How is the further processing of your application progressing?
LUCA will make every effort to respond to your request within a reasonable time. This can be done by responding to your request and providing you with the requested information and/or taking the necessary actions. On the other hand, LUCA may also decide that it is not to be able to comply with your request, subject to a thorough justification.
LUCA may also request additional information in order to be certain of the applicant's identity.
Use of the website
Access to and use of the website are subject to the following modalities and conditions, subject to all rights.
General
All modalities and conditions as mentioned below relate to the LUCA School of Arts VZW website with domain name www.luca-arts.be and all other websites, satellite sites or web pages developed by LUCA School of Arts, or to be developed in the future. As soon as you access or use any LUCA School of Arts website, you are supposed to have read and explicitly agreed to our Terms of Use. If you do not agree with the content of these terms of use, we request that you no longer consult the website.
If one clause of these terms of use is not applicable or is contrary to a clause of mandatory law, this non-applicability will not affect the validity or applicability of the other clauses.
Access to and use of the website
LUCA School of Arts makes every effort to ensure, as far as possible, access to the website, without any guarantee whatsoever. However, this access can be interrupted for any reason and without prior notice or motivation by LUCA School of Arts.
The user is responsible for the proper functioning of his/her IT system and his/her Internet access. The user explicitly undertakes not to disturb the optimal functioning and security of the website, for example by using viruses and/or other harmful files or data and/or by accessing files or data to which he/she has no access.
LUCA School of Arts always reserves the right to completely or partially deny a user access to the website unilaterally and without prior notification or motivation. The user cannot hold LUCA School of Arts responsible for this.
The user is forbidden to supplement, change, delete, replace and/or improve the information that LUCA School of Arts makes available on the website, in whole or in part.
Guarantees and liability
The website is intended to provide general information about LUCA School of Arts. It is not adapted to personal or specific circumstances and therefore cannot be considered as personal, professional, legal advice or equivalent to the user.
Although LUCA School of Arts endeavours to provide information that it believes is current and correct, LUCA School of Arts does not guarantee that all information is adequate, correct and complete, nor that the website is comprehensive.
Under no circumstances can LUCA School of Arts be held liable for direct or indirect damage that could result from:
- consulting and/or using the information offered on the website or websites to which this website refers or
- the absence of specific information.
- Nor does LUCA School of Arts guarantee that the website or the server making the website available is free from computer viruses.
LUCA School of Arts is not responsible for the content of job offers submitted by employers on our website. LUCA School of Arts cannot be held responsible for the content of the vacancies, as to the correctness of the information, nor for direct or indirect damage resulting from the information offered in these vacancies.
LUCA School of Arts always has the right to change, improve, delete and/or change the content of the website without prior notice.
LUCA School of Arts may provide links to other websites on its website. However, LUCA School of Arts is never responsible for, and cannot be held to investigate, evaluate, or provide any guarantees regarding the content of these websites. LUCA School of Arts can therefore in no way be held responsible for direct or indirect damage that would be caused by consulting and/or using the information offered on the above-mentioned websites.
If LUCA School of Arts is charged or if costs are imposed on LUCA School of Arts as a result of misuse of this website or a breach of these terms of use by the user, the user undertakes to indemnify LUCA School of Arts for all costs, claims, loss and damage (including legal costs).
Intellectual property rights
The user has the right to consult the information on the website (including the editorial material, the informative texts, photos, illustrations, drawings and other graphic material, names, logos, trademarks and other brands) and download and reproduce only for personal use, provided he/she mentions the source, in accordance with the provisions of the law on copyright and related rights of 30 June 1994.
However, this permission does not apply to texts explicitly mentioning a restriction of use. Reproduction or use of multimedia information (sound, images, software, etc.) always requires prior written permission from LUCA School of Arts.
Under no circumstances may the user use the content of the website for commercial purposes, nor distribute it or communicate it to third parties, for-profit purposes or otherwise, without the prior explicit written permission of LUCA School of Arts.
LUCA School of Arts reserves all current and future intellectual property rights on the website itself and on the information made available.
Confidentiality
All messages, information, data, material, etc. that the user provides to the administrator of the LUCA School of Arts website, unsolicited and of his own agreement, including the data or reactions regarding the content of this website, are considered non-confidential. LUCA School of Arts disclaims any obligation regarding the action to be taken on the above communications and general responses and data. LUCA School of Arts has the right to use all of the above messages, responses and data in its discretion, taking into account the restrictions provided by the Law of 8 December 1992 on the protection of privacy with regard to the processing of personal data.
The user agrees that LUCA School of Arts can use the ideas, concepts, knowledge and techniques contained in the information, data, material, etc. that he/she has communicated to LUCA School of Arts for any purpose.
Applicable law and competent court
All disputes related to or arising from the use of the website as well as from the application and interpretation of these terms and conditions of use are governed by Belgian law, whereby the courts of the judicial district of Brussels have exclusive jurisdiction.
Contact details
For any questions about the content and/or use of the website, the user can contact artoffice@luca-arts.be
Emails
Emails from LUCA School of Arts employees may contain confidential information and are therefore intended only for the addressee(s). If you have received an email from one of our employees by mistake, please contact the sender and delete this email, including any attachments, from all computers.