Bruxelles-Propreté (‘the Agency’) is the Regional Agency for Cleanliness, a public interest body created by the ordinance of 19 July 1990 creating the Regional Agency for Cleanliness.
The Agency is fully committed to protecting the privacy and personal data of its users. The main purpose of this privacy policy is to clearly define the commitments and measures adopted by the Agency to ensure the confidentiality, integrity and availability of the personal data it processes. However, it is also intended to inform you transparently about the data we collect, the reason for its collection, how it is used and your rights as a user regarding this data.
The privacy policy applied by Bruxelles-Propreté regarding Personal Data covers the data obtained from:
- Visits to and use of this Website (‘the Website’);
- Visits to Bruxelles-Propreté Recyparks (‘Recyparks’);
- Requests for Bruxelles-Propreté to remove bulky items;
- Collection services provided to professionals, supplementing the general terms and conditions of sale applicable to contracts established for this purpose;
- The receipt and registration of applications sent to Bruxelles-Propreté electronically (via the Website or by email), via job sites, or via Actiris;
- Running awareness campaigns and interest-based communities around Bruxelles-Propreté projects.
This privacy policy has been drawn up in accordance with:
The obligations defined by Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR), and in the Law of 30 July 2018 on the protection of individuals with regard to the processing of personal data, and in compliance with European Directive 2009/136/EC (the ‘e-Privacy Directive’). We also comply with the Belgian Law of 21 March 2007 on the use of surveillance cameras.
1. Data subjects
For the purposes of this privacy policy, the data subjects are:
- In the case of the Website: anyone using the Website;
- In the case of a Recypark: anyone visiting the Recypark and identifiable as such;
- In the context of requests for the removal of bulky items: anyone using the services of Bruxelles-Propreté for the removal of bulky items;
- In the case of the receipt and registration of applications: anyone who, for recruitment purposes, applies for a job electronically (via the Website or by email), via job sites, or via Actiris;
- In the context of the running of interest-based communities: anyone wishing to join and participate an interest-based community.
2. Types of data collected
2.1. Use of the Website
The types of Personal Data collected by the Website, directly or through third parties, are:
- Usage data, to the extent that such data contains the visitor’s IP address, and data from cookies collecting information for statistical purposes. Such data may include the IP addresses or domain names of computers used by the data subject using the Website, Uniform Resource Identifier (URI) addresses, the time of the request, the method used to submit the request to the server, the size of the file received in response, the numerical code indicating the server response status (favourable result, error, etc.), the country of origin, the characteristics of the browser and operating system used by the IP address concerned, various details relating to the time per visit (e.g. time spent on each page on the Website) and details relating to the path taken within the Website with special reference to the sequence of pages visited, and other parameters relating to the data subject’s operating system or IT environment;
- Where applicable, the information entered by visitors in the forms made available to them for the management of questions and complaints to Bruxelles-Propreté and the management of applications for student jobs at Bruxelles-Propreté.
The Bruxelles-Propreté Website also includes a section dedicated to its professional customers, MyProZone. To the extent that access to this section of the site requires prior user authentication, the privacy policy relating to this section of the Website is provided on the home page of the MyProZone section.
2.2. Visiting a Recypark
The types of Personal Data collected during visits to a Recypark are:
- The vehicle registration number;
- The date and time of visiting the Recypark;
- The type of vehicle in the case of a trailer or van;
- The postcode of the person’s home address.
The identity of the person (surname, first name) is not collected during the visit.
Furthermore, images from surveillance cameras may also be collected during a visit to a Recypark. In accordance with the Camera Law (the above-mentioned Law of 21 March 2007), the viewing and distribution of these images are strictly controlled.
2.3. Requests for removal of bulky items
In the context of requests for the removal of bulky items, Personal Data concerning the person using the services of Bruxelles-Propreté for the removal of bulky items is also collected. The types of Personal Data collected in the context of these requests are:
- Identity (surname, first name, telephone number, email address);
- Collection address and postcode of the person’s home.
2.4. Job applications
Personal data is also collected in the context of the receipt and registration of applications sent to Bruxelles-Propreté electronically (via the Website or by email), via job sites, or via Actiris, and in order to process applications for jobs at Bruxelles-Propreté. The following types of Personal Data may be collected during the management of recruitment and hiring of personnel for Bruxelles-Propreté:
- Identity (surname, first name, telephone number, email address);
- Curriculum vitae, including the personal data that the candidate has included;
- Household composition;
- National register data and/or unique national identification number;
- Residence and/or work permit (in the case of foreign nationals).
2.5. Interest-based community
In connection with the running of an interest-based community around Bruxelles-Propreté projects, Personal Data is also collected from citizens wishing to join such a community. The types of Personal Data that may be collected in the context of communication about current environmental projects and any involvement of citizens in their implementation are limited to the data subject’s surname, first name and email address.
3. Methods and place of data processing - Recipients
The Data Controller will process data subjects’ data in an appropriate manner and take all necessary security measures to prevent unauthorised access, disclosure, modification or destruction of the data.
Data processing will be carried out using computers or IT tools and according to procedures and organisational methods closely linked to the purposes described in point 4 of this document.
Access to the personal data to which this policy relates, in addition to that reserved for the Data Controller, may in certain cases be granted to third parties (such as third-party providers of technical services, electronic messaging services, the design or running of websites or IT hosting) designated, where applicable, as data processors by the Data Controller. The list of these third parties may be requested at any time from the Data Controller with respect to processing operations affecting the data subject.
In the case of other personal data collected: the data is processed at the Data Controller’s registered office and in any other place where the Data Controller carries out its activities, by personnel authorised to carry out such processing.
4. Purposes of data collection and legal bases
4.1. Use of the Website
Data relating to the data subject is collected to enable the Data Controller to provide the services described in the rest of this document, to the extent that these rely on communication through the Website, as well as to meet the following objectives, exhaustively listed: analysis of Website traffic, management of questions and complaints.
The existence of Websites outside the specific scenarios for the processing of personal data mentioned in the rest of this document results from the ordinance of 19 July 1990 creating the Regional Agency for Cleanliness.
4.2. Visiting a Recypark
Data relating to the data subject’s vehicle is collected for the purposes of processing any customer complaint, for the purposes of any investigation (relating to assault, material damage, fly-tipping or unauthorised waste) by the Bruxelles-Propreté Investigation and Reporting Service or by the judicial or police authorities, and for the purposes of recording Recypark usage statistics.
Camera images are also collected to prevent, record or detect any offence against Bruxelles-Propreté personnel members or any other person present, as well as against the property of Bruxelles-Propreté or of third parties present on the site. These images are also collected to ensure the safety and health of Bruxelles-Propreté workers. The collection of camera images is always undertaken in strict compliance with the law of 21 March 2007 regulating the installation and use of surveillance cameras.
4.3. Requests for removal of bulky items
In the context of requests for Bruxelles-Propreté to remove bulky items, data relating to the data subject is collected for the purposes of processing such requests.
The identity data makes it possible to identify the person using the services of Bruxelles-Propreté for the removal of bulky items, and to link the collection address and the residential postcode with the person. The telephone number is requested in order to send a confirmation SMS and to contact the person using the services of Bruxelles-Propreté on the day of the appointment for the removal of the bulky items.
4.4. Job applications
In the context of the receipt and registration of applications sent to Bruxelles-Propreté electronically (via the Website or by email), via job sites, or via Actiris, data relating to the data subject is collected for the purposes of processing applications for current or future employment.
Further information regarding the collection or processing of Personal Data may be requested from the Data Controller at any time. Please see the contact information in point 9 below.
4.5. Interest-based community
In connection with the running of an interest-based community relating to Bruxelles-Propreté projects, data relating to the data subject is collected in order to allow the Data Controller to provide information about actions undertaken in connection with the theme for which the interest-based community has been formed. If certain actions lead to registration for an event or activity, for example, the data is also processed in order to record any participation of members of the community in actions or events organised in this context. This data will not be passed on to third parties without the explicit consent of the data subject.
5. Storage period
Personal Data is kept for as long as necessary to achieve the purposes defined in point 4 of this document. The data subject may ask the Controller at any time to suspend the processing or delete the data.
5.1. Use of the Website
In connection with the analysis of Website traffic, the data collected for the purposes of Website visit statistics is anonymised and kept for a period of three years.
Personal Data collected for the purposes of responding to any question or complaint is kept for a period of seven years after the last contact with the citizen concerned.
5.2. Visiting a Recypark
In connection with a visit to a Recypark, the Personal Data collected for the purposes of receiving the service provided by the Recypark is kept for:
- 12 months in the case of vehicle registration numbers unless it is necessary in connection with legal disputes or any investigation by the Investigation and Reporting Service;
- 30 days in the case of video surveillance images unless it is necessary in connection with legal disputes or any investigation by the Investigation and Reporting Service.
In the context of a visit to a Recypark, Personal Data collected for the purposes of responding to any question or complaint is kept for a period of seven years after the last contact with the citizen concerned.
In the context of a visit to a Recypark, Personal Data collected in connection with a legal dispute or for the purposes of an investigation by the Investigation and Reporting department of Bruxelles-Propreté is kept as follows:
- Documents relating to misdemeanours are kept for a period of 15 years;
- Documents relating to minor breaches of the law are kept for a period of 15 years.
5.3. Requests for removal of bulky items
In the context of requests for Bruxelles-Propreté to remove bulky items, the personal data collected is kept for a period of seven years after the last contact with the citizen, in accordance with the statutory limitation periods for tax matters.
Invoicing data is kept for a period of ten years, in accordance with the requirements of the Ordinance of 23 February 2006 on the provisions applicable to budgeting, accounting and auditing.
5.4. Job applications
In the context of the receipt and registration of applications sent to Bruxelles-Propreté electronically (via the Website or by email), via job sites, or via Actiris, Personal Data is kept as follows:
- Personal Data collected in connection with successful applications is included in the future personnel member’s records and kept for up to one year after his/her departure from Bruxelles-Propreté;
- Personal Data collected in connection with unsuccessful applications is deleted at the end of the recruitment procedure.
If a job application is received via Actiris and the application is successful, some Personal Data (such as the person’s identity of the data subject and the date of commencement of employment) are communicated to Actiris so that his/her file at Actiris can be closed.
Contact Actiris for questions concerning the processing of an applicant’s data by Actiris when the application has been submitted to Actiris.
5.5. Interest-based community
In connection with the running of an interest-based community relating to Bruxelles-Propreté projects, the Personal Data of interested citizens are kept for the duration of a legislative period. At the end of each legislative period, after a maximum of five years, the data is deleted, unless the data subject expresses his/her wish to remain part of the community during the next legislative period.
6. Artificial intelligence technology
In connection with efforts to objectively identify and improve public cleanliness, from 19 March 2024 to 18 July 2024 Bruxelles-Propreté will test an artificial intelligence (‘AI’) technology system in the context of a partnership with the Swiss company CortexIA. This solution allows an advanced analysis of urban cleanliness to be performed using AI to obtain urban data and measure the level of cleanliness of urban spaces.
In this context, image data captured by four cameras placed on part of the vehicle fleet is processed in collaboration with CortexIA (see its privacy policy: https://www.cortexia.ch/privacy-policy/), which implements numerous measures to safeguard the data collected directly or indirectly (accidental collection of images likely to contain personal information).
7. Data subject’s rights
Under the General Data Protection Regulation (GDPR), data subjects have specific rights regarding the processing of their personal data.
You have the right of access, which means that you can obtain, free of charge, a copy of your processed personal data; you will be asked to provide your surname and first name and a current postal address in this connection.
If we need to confirm your identity, we may ask you for a copy of your identity card. You can remove your national registration number, your photo and the machine-readable area from this copy.
Requests must be sent to the Data Controller at the address indicated in point 9 below.
You also have the right to ask to correct or delete your personal data, or to ask for the processing of this data to be stopped, under certain conditions; you also have the right to object to the processing of your data.
If you believe that we have not responded to your request adequately, you also have the right to submit a complaint to the data protection authority, by clicking on this link: https://www.autoriteprotectiondonnees.be/citoyen/agir/introduire-une-plainte
8. Changes to this privacy policy
The Data Controller reserves the right to modify this privacy policy at any time, with immediate effect.
It is advisable to consult this page regularly, checking the date of the most recent change as indicated in point 10 below. If a data subject objects to any changes to this policy, he/she may ask the Data Controller to delete his/her Personal Data. Unless otherwise stated, the privacy policy in force at the time applies to all Personal Data that the Data Controller holds about the data subject.
9. Detailed cookie policy
We invite you to read our cookie policy at: https://www.arp-gan.be/en/politique-de-cookies
10. Data Controller
Regional Agency for Cleanliness, Bruxelles-Propreté
Avenue de Broqueville, 12
1150 Brussels
Data Controller’s contact email address: info@arp-gan.be
11. Data protection officer
Regional Agency for Cleanliness, Bruxelles-Propreté
The DPO
Avenue de Broqueville, 12
1150 Brussels
DPO’s contact email address: dpo@arp-gan.be
12. Date of this privacy policy:
21/03/2024
