This document is to be used where the World Association of Nuclear Operators – Paris Centre (hereinafter referred to as "WANO Paris Centre") processes personal data relating to its employees, seconded staff, workers, contractors, board members and other third parties that work with WANO Paris Centre, as well as those of the companies that are member of WANO and affiliated to the WANO Paris Centre.

WANO Paris Centre is committed to protecting the privacy and security of personal information. The following policy guideline is intended to provide individual persons (Data Subjects) with information on how their personal data will be collected and processed by WANO Paris Centre, including collect of data from WANO website users and subscribers.

WANO Paris Centre is not responsible for the content or the privacy policies of websites to which it may provide links. WANO Paris Centre uses all reasonable precautions to keep the personal information disclosed to us secure and to disclose such information only to responsible third parties and affiliates after permission from the user. 

In case of questions regarding this Privacy Policy please contact the WANO Paris Centre at wanopc@wanopc.org or by writing to us. Please address any correspondence to WANO Paris Centre, 10-12 Cours Michelet, 92800 Puteaux, France.

 

WANO Paris Centre collects personal data through application processes for employment, secondment or participation in activities that are organised by, or with, WANO Paris Centre. Data collection is either direct from the individual or from their employer. WANO Paris Centre may also collect additional information from third parties, including, among others, former employers, credit reference agencies or other agencies that perform background checks.

 

WANO Paris Centre collects additional personal information in the course of activities undertaken on behalf of WANO Paris Centre.

 

Personal data is processed for purposes relating to employment, secondment or participation in activities organised by, or with, WANO Paris Centre, and any resulting engagement with one of the WANO Offices, WANO Regional Centres or WANO Member Organisations.

 

Personal Data

Where appropriate for WANO Paris Centre purposes, data are collected and processed pertaining to: name, gender, date of birth, place of birth, country/area of birth, country of citizenship, home address, telephone/facsimile number of home and affiliated entities, e-mail address, emergency contact, work history, resume, photo ID (passport, driver’s license, resident card, etc.), bank account, job title, employer, place of current assignment (if different from actual employer), size of clothing and shoes, CCTV footage and information obtained through electronic means (such as swipe card records). WANO Paris Centre may also collect information where users or subscribers participate in certain WANO Paris Centre activities, such as questionnaires and surveys, and through the use of cookies. When users request pages from our server, our web server automatically collects some information about them, including their IP addresses. These addresses are used by computers on the network to send the requested pages to users.

Sensitive Data

In the case of participation in activities organised by, or with, WANO Paris Centre, additional data are collected and processed that are required to gain security clearance for access to nuclear facilities and radiation controlled areas, such as: individual exposure dose history, medical history, criminal records, drug test results, blood test results, educational history and credit reliability.

In the case of workshops, seminars or conferences organised by, or with, WANO Paris Centre, data on dietary restrictions may also be collected.

Personal Data relating to Family Members

In case of individuals participating to WANO Paris Centre activities who are accompanied by family members, personal data relating to family members may be required. This may include name, gender, date of birth, place of birth, country/area of birth, country of citizenship, home address, emergency contact information and photo ID.

 

WANO Paris Centre will only use personal information when the law allows this. Most commonly, WANO Paris Centre will use personal information in the following circumstances:

·         To perform the contract WANO Paris Centre has entered into with the individual

·         To comply with a legal obligation (such as complying with obligations under employment law or health and safety regulations)

·         Where it is necessary for the legitimate interests of WANO Paris Centre (or those of a third party) and the individual’s interests and fundamental rights do not override those interests. These legitimate interests will be to enable WANO Paris Centre and/or its Member Organisations to fulfil their mutual obligations with regards to carrying out:

o    Peer Reviews, Member Support Missions, Training and Development, Working Groups or any other WANO Paris Centre activity that supports safe operation of our Members’ nuclear facilities

o   Secondments;

o   Direct labour contracts.

 

WANO Paris Centre may also use personal information in the following situations:

·        To protect the individual’s interests (or someone else's interests), such as in medical emergencies.

·        When needed in the public interest or for official purposes.

·         When the individual has given consent to use the data for a specified purpose. In limited circumstances, WANO Paris Centre may approach the individual for written consent to process sensitive data.

 

The situations in which WANO Paris Centre processes personal data are set out in the table below. The table lists the purpose and lawful basis for which personal information is being processed, what categories of data are involved, and how long personal data is retained.

 

Purpose	Category	Lawful Basis	Retention Period
Verification of identity	Personal data	Legitimate interests in verifying who the individual is, prior to engagement with WANO Paris Centre. Contractual necessity.	·       Duration of employment, secondment, contractual agreement or WANO mission. ·       Any additional period necessary in accordance with record retention obligations under applicable laws.
Assessment of eligibility for each engagement	Personal data	Legitimate interests in ensuring that the individual is suitable for the engagement. Contractual necessity.	·       Duration of employment, secondment, contractual agreement or WANO mission. ·       Any additional period necessary in accordance with record retention obligations under applicable laws.
Travel arrangement	Personal data	Contractual necessity	·       Duration of logistical preparation and travel itself.
Workshops, seminars	Sensitive data		·         Duration of logistical preparation and event itself.
Visa applications	Personal data	Contractual necessity	·         Duration of logistical preparation and travel itself. ·         Any additional period necessary in accordance with record retention obligations under applicable laws.
Salary payment, expense reimbursements and daily allowances	Personal data	Contractual necessity	·       Duration of employment, secondment, contractual agreement or WANO mission. ·         Any additional period necessary in accordance with record retention obligations under applicable laws.
Access to WANO Member nuclear facilities or corporate offices	Personal and sensitive data	Contractual necessity	·       Duration of logistical preparation and WANO mission itself. ·       Any additional period necessary in accordance with record retention obligations under applicable laws.
Health and safety obligations, including radiation exposure restrictions	Personal and sensitive data	Compliance with legal obligation	·       Duration of employment, secondment, contractual agreement or WANO mission. ·       Any additional period necessary in accordance with record retention obligations under applicable laws.
Record activities implemented by WANO Paris Centre	Personal data	Legitimate interests in monitoring and analysing WANO Paris Centre activities	·       Permanent historical record.
Future participation in WANO Paris Centre activities, missions, or meetings	Personal data	Legitimate interests of engaging experienced personnel for WANO Paris Centre engagements. Contractual necessity	·         10 years
Participation in WANO Paris Centre governance activities	Personal data	Compliance with legal obligation.	·         Association life time
Inclusion of employees in company benefit schemes	Personal data	Contractual necessity	·       Duration of employment. ·         Any additional period necessary in accordance with record retention obligations under applicable laws.
Any other activity necessary to fulfil the individual’s employment, secondment or contractual agreement with WANO Paris Centre	Personal data	Contractual necessity	·       Duration of employment, secondment, contractual agreement or WANO mission. ·         Any additional period necessary in accordance with record retention obligations under applicable laws.
WANO Paris Centre website users and subscribers during their registration for corporate events, workshops and seminars, or any other event hosted by WANO Paris Centre	Personal data	Contractual necessity	·       Duration of logistical preparation and WANO mission itself. ·         Any additional period necessary in accordance with record retention obligations under applicable laws.

 

 

Personal information is retained for as long as necessary to fulfil the purposes they are collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Details of retention periods for different aspects of personal information are set out in the table above, and are available in the Data Classification, Data Handling and Retention Period Procedure, which is available from WANO Paris Centre upon request.

To determine the appropriate retention period for personal data the following factors are considered: the amount, nature and sensitivity of the personal data; the potential risk of harm from unauthorised use or disclosure of personal data; the purposes for which personal data are processed and whether those purposes are achievable through other means; and the applicable legal requirements.

In some circumstances personal information may be anonymised so that it can no longer be associated with individuals, in which case such information may be used without further notice. Once the individual is no longer an employee, secondee, worker or contractor of the company, personal information is retained and securely destroyed in accordance with our data retention procedure and applicable laws and regulations.

Where necessary for the purposes set out in this policy, personal data may be shared with WANO London Office, WANO Shanghai Office, WANO Atlanta Centre, WANO Tokyo Centre, WANO Moscow Centre, and relevant WANO Member Organisations.  

 

WANO Paris Centre will not reveal any personal information that users provide to any third party without their permission. WANO Paris Centre uses users’ IP addresses to help diagnose problems with our server and to administer the website. This information does not contain any details that can identify users personally.

WANO Paris Centre may disclose users’ personal information if, in our opinion, such disclosure is required

 • by law

 • to protect and/or defend WANOPC’s rights and/or

 • to protect the personal safety of any individual.

Personal data are also shared with third party suppliers as necessary to support the activities set out in the section ‘Purpose’ above. Information on such third parties shall be made available by WANO Paris Centre upon request.

 To the extent that the concerned WANO Office, WANO Regional Centre or WANO Member Organisation are not located within the European Economic Area (EEA), and to the extent that personal data is subject to the terms of the General Data Protection Regulation, the processing of personal data will be subject to Standard Contractual Clauses (SCC) as agreed between the WANO Offices, WANO Regional Centres and WANO Members. Copies of applicable SCC may be obtained from WANO Paris Centre upon request.

WANO Paris Centre maintains adequate organisational and technical security measures to protect personal data from unauthorised access, loss, misuse, disclosure, alteration and destruction.

 

Individual Duty to Communicate Changes

It is important that the personal data that WANO Paris Centre holds is accurate and current. Individuals are requested to inform WANO Paris Centre if their personal information changes during their working relationship with WANO Paris Centre.

Individual Rights in Connection with Personal Information

Under certain circumstances, by law each individual has the right to:

·        Request access to their personal information (commonly known as a "data subject access request"). This enables individuals to receive a copy of the personal information WANO Paris Centre holds and to check that the data are being lawfully processed.

·        Request correction of the personal information. This enables individuals to have their personal information corrected in case it is incomplete or inaccurate.

·        Request erasure of personal information. This enables individuals to request the deletion or removal of personal information where there is no valid reason to retain it. Individuals also have the right to request deletion or removal of personal information where they have exercised their right to object to processing (see below).

·        Object to processing of personal information. This enables individuals to object to WANO Paris Centre processing individual information relying on a legitimate interest (or those of a third party). Individuals also have the right to object where WANO Paris Centre is processing personal information for direct marketing purposes.

·        Request the restriction of processing of personal information. This enables individuals to request the suspension of personal information processing pending verification of its accuracy or the reason for processing it.

·        Request the transfer of personal information to another party.

Individuals wanting to review, verify, correct or request erasure of their personal information, object to the processing of their personal data, or request that WANO Paris Centre transfer a copy of their personal information to another party, are requested to contact the WANO Paris Centre in writing.

Individuals will not have to pay a fee to access their personal information or to exercise any of the other rights. However, WANO Paris Centre may charge a reasonable fee if the request for access is clearly unfounded or excessive. Alternatively, WANO Paris Centre may refuse to comply with the request in such circumstances.

WANO Paris Centre may need to request specific information from individuals to help confirm their identity and ensure their right to access the information or to exercise any of the other rights. This is an appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

Right to Withdraw Consent

In the limited circumstances where individuals may have provided consent to the collection, processing and transfer of personal information for a specific purpose, at any time they have the right to withdraw that consent for that specific processing. To withdraw consent, individuals are requested to contact the WANO Paris Centre in writing. Once WANO Paris Centre has received notification of the withdrawal of consent, the personal information will no longer be processed for the purpose that was originally agreed to, unless a legitimate basis exists for continued processing.

 

Failure to Provide Personal Information

In case individuals fail to provide certain personal information when requested, WANO Paris Centre may not be able to perform its contractual obligations or may be prevented from complying with its legal obligations.

 

Right to Lodge a Complaint

Any individual has the right to complain about the processing of their personal data to a Supervisory Authority.

 

WANO Paris Centre will only use personal information for the purposes for which it was collected, unless WANO Paris Centre reasonably considers that it is needed for another reason and that reason is compatible with the original purpose. If WANO Paris Centre needs to use personal information for an unrelated purpose, WANO Paris Centre will notify you and will explain the legal basis which allows this usage. WANO Paris Centre may process personal information without individual’s knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

 

WANO Paris Centre reserves the right to update this privacy policy at any time, and will provide individuals with a new privacy policy when any substantial updates are made. WANO Paris Centre may also provide notification to individuals in other ways about the processing of personal information.

 

For any questions regarding this policy, or to exercise individual rights regarding the processing of personal data, please contact WANO Paris Centre at wanopc@wanopc.org or in writing to WANO Paris Centre, 10-12 Cours Michelet, 92800 Puteaux, France.