1. General Information
1.1 Contact details
Space Society Twente is a student association at the University of Twente. The association is registered with the The Netherlands Chamber of Commerce under number 72533994. Space Society Twente can be visited at Drienerlolaan 5, 7522 NB in Enschede. Contacting the association is possible via email: info@spacesocietytwente.nl.
1.2. Storage period of data
Space Society Twente retains personal data of its members for the duration of the membership, unless otherwise specified in the next chapters. Even after termination of membership, it is possible personal data will be retained in backups up to one year.
1.3. Rights of the involved
Based on the Dutch adaption (AVG) of the EU General Data Protection Regulation (GDPR), every citizen has the following rights:
- Right of inspection (AVG Article 15)
- Right of rectification (AVG Article 16)
- Right to be forgotten (AVG Article 17)
- Right to restriction of processing (AVG Article 18)
- Right to transfer data (AVG Article 20)
- Right to objection (AVG Article 21)
- Right to withdraw consent (AVG Article 7, Section 3)
- Right of objection with AP (AVG Chapter 2)
1.4. Definition of legal grounds
The next chapters will give a full overview of all data processing activities of Space Society Twente. A brief description will be given for each processing activity, as well as one (or more) legal grounds (a, b, c, d, e or f) on which the data processing activity is grounded. These legal grounds originate from the AVG, Article 61. Below follows a short overview of these legal grounds.
a. the person concerned has given permission for the processing of their personal details for one or more specific purposes;
b. the processing is necessary for the execution of an agreement in which the person concerned is a party, or to take measures on request of the person concerned before the agreement is completed;
c. the processing is necessary to comply with a legal obligation of the processing party.
d. the processing is necessary to protect the vital interests of the person concerned or of another natural person;
e. (This legal ground is meant for government agencies, therefore it can never be used by Space Society Twente)
f. the processing is necessary for the representation of legitimate interests of the processing party or of a third party, except for when the interests or the fundamental rights and freedoms of the person concerned that relate to the protection of personal data, outweigh those interests, especially when the person concerned is a child.
2. Collected data
2.1. Membership administration
2.1.1. Full name
Legal ground b, minimal execution of membership agreement
The name of a member is recorded for the purposes of correspondence between the member and Space Society Twente. Names of members are preserved indefinitely, as this information is directly connected to other documents or data that might include the name of a member, such as minutes of the General Members Assembly.
Legal ground a, explicit permission active members
All members have the ability to become active members. They are, however, not required to do so. Becoming an active member results in the name of the member to be recorded in external support systems, as outlined in section 3.2.
2.1.2. Email Address
Legal ground b, minimal execution of membership agreement
The primary method of correspondence between Space Society Twente and its members is email. This method of communication is required per the statutes of Space Society Twente, as it serves the function of announcing and gathering the members for a General Members Assembly.
Legal ground a, explicit permission for information mailing
Members of Space Society Twente have the option to select different types of information mailings. Specifically, options on activity mailings, periodic newsletters and partner mailings are among the options offered. Explicit permission for these types of communication can be provided by members on their profile page and during registration.
Legal ground a, explicit permission active members
All members have the ability to become active members. They are, however, not required to do so. Becoming an active member results in the email address of the member to be recorded in external support systems, as outlined in section 3.2.
2.1.3. Date of Birth
Legal ground c, compliance with minimum age requirements for online services
Every person that wishes to use the online services of Space Society Twente has to be at least sixteen years old, in accordance with legislative requirements. Space Society Twente uses the date of birth of a person to determine if a person has reached the minimum age requirements.
Legal ground a, explicit permission active members
All members have the ability to become active members. They are, however, not required to do so. Becoming an active member results in the birthdate of the member to be recorded in external support systems, as outlined in section 3.2.
2.1.4. Photographs
Legal ground f, grounded interest in publication of promotion photos
For the purposes of the promotion and member retention, Space Society Twente demonstrates a grounded interest in the publication of pictures taken at events where the association is involved.
Legal ground a, explicit permission for use of profile picture
Members are free to upload and change a representative profile picture of themselves at any given time. For members without a public function, uploading a profile picture is not required.
Legal ground f, grounded interest in publication of active member profile pictures
Active members serve a public function. As such, active members are requested to upload a representative profile picture of themselves. Profile pictures of active members are recorded in external support systems, as outlined in section 3.2. Publication of members’ profile pictures can be avoided if members can present reasonable arguments demonstrating that their right to privacy outweighs the grounded interest of Space Society Twente in this matter.
2.1.5. Student Status
Legal ground f, monitoring of student participation
Space Society Twente has a grounded, mostly financial, interest in the monitoring of student participation. The participation of students indirectly influences the subsidy received by the association from University of Twente entities and affiliates, and therefore is key to the continuation of the services offered to its members.
2.1.6. Date of Registration
Legal ground f, member administration
Space Society Twente records when a person becomes a member of the association for the purposes of monitoring year-over-year member count. Demonstrating growth, or detecting stagnation, is key to the continuation of the services offered to the association's members, and therefore provides ample reason for the recording of this information.
2.1.7. Memberships
Legal ground b, minimal execution of membership agreement
Space Society Twente registers membership of its members. This membership information includes the year for which the membership was requested, its payment properties and for whom the membership was paid for. This information is required for proper execution of the membership agreement, as specified in the statutes of Space Society Twente.
2.1.8 Address, Postal Code, City, Province and Country
Legal ground b, minimal execution of membership agreement
In case the primary method of communication (email) is not available, Space Society Twente will use the postal address of its members. The address is thus stored by Space Society Twente.
2.2. Active members administration
2.2.1. Functions
Legal ground a, explicit permission active members
All members have the ability to become active members. They are, however, not required to do so. Becoming an active member results in the function of the member to become publicly available and recorded in external support systems, as outlined in section 3.2.
3. Personal data usage
In this chapter, the various uses of collected personal data are outlined. The purposes listed in this chapter are in addition to those listed in Chapter 2, which are mostly concerned with (active) member administration. As such, (active) member administration and its purpose will not be listed in this chapter, even though it is one of the usages of the collected personal data.
3.1. Financial interests of Space Society Twente
Legal ground f, obtaining financing and subsidies
Space Society Twente regularly receives subsidies and other means of financing from third-party organizations based on various key performance indicators. These indicators are based on anonymized personal information of the association's members.
3.2. Board and committee work
Legal ground f, publication of board and committee member information
Members of Space Society Twente who have chosen to become active within the association, have a public function. As such, they are accountable to the extent of their responsibilities. The names of these members are therefore published together with their responsibilities within the association. In addition, to ensure continuity of Space Society Twente and its associated committees, functions are made transferable between members. To facilitate this transition, external support systems are utilized. As such, certain personal data will be transferred to these external services, as outlined in section 2 of this document.
3.3. Processing of purchases and activities
3.3.1. Enrollment forms for activities
Legal ground a, execution of activities
For some activities it is necessary to collect extra information to make sure the activity runs smoothly. This information is only used for the execution, settlement and evaluation of that activity and is removed afterwards. During these processes, personal information of participants as well as activity-related data might be shared with third parties and other external support systems used by Space Society Twente.
3.3.2. Transfer of Personal Details to Third Parties due to the Nature of Activities
Legal grounds a and b, corresponding obligations after explicit consent of person
Because of the nature of some activities, which may or may not be based in part on the processing of personal details by third parties, in some cases personal details are shared with external parties. The personal details are only shared after explicit permission from the person concerned at the time of enrollment for the activity. The shared information is limited to the parts that are found to be strictly necessary for the concluded agreement.
3.3.3. Publication of Pictures
Legal ground f, internal and external promotion of activities
Pictures are made at almost all activities of Space Society Twente. The photographed people are not explicitly mentioned by name. The name of the photographer is often shown with the pictures. At the request of a person with a reasonable interest, a picture may be deleted from the website.
3.4. Meetings
3.4.1. Acquisition and Storage of Name in the Context of GMA and BM Authorizations and Absence
Legal ground c, keeping of authorizations
If a member submits a notice of absence for a meeting within Space Society Twente, or authorizes someone else for that meeting, then Space Society Twente is legally required to save these absences and authorizations.
3.4.2. Storage and Publication of Names in GMA, BM and Committee Minutes
Legal ground c and f, keeping of minutes
Minutes are kept of important meetings at Space Society Twente. At some meetings this is legally required (the General Members Assembly and Board Meetings), and at other meetings this is desirable. These minutes are shared with all or a part of the members of Space Society Twente. The names of the attendees of these meetings will be published in these minutes.
3.5. Honorary Members and Members of Merit
3.5.1. Publication of Names of Honorary Members and Reasons of Honorary Memberships
Legal ground f, ‘honoring’ honorary members
The names of the honorary members of Space Society Twente are publicly published on the website in combination with a description of why the member became a Honorary Member. Space Society Twente does this to remember its honorary members.
3.5.2. Publication of Names of Members of Merit and Description of Merits
Legal ground f, ‘honoring’ members of merit
The names of the members of merit of Space Society Twente are publicly published on the website in combination with a description of why the member became a Member of Merit. Space Society Twente does this to remember its members of merit.
3.6. Digital facilities
3.6.1. Processing Logs
Legal ground f, error recovery and privacy assurance
A log is kept for various events that occur in the systems of Space Society Twente. These logs might contain personal details. These logs are used to retrieve previous versions of, among other things, pages, documents or other fields in the case of erroneous or incorrect data. The logs are also used as a documentation of the operations on, or processing of a certain object.
3.6.2. Error Logs
Legal ground f, error recovery and fixing bugs in software
Many of our computer systems and applications keep error logs, in which details about error messages or problems is saved. These logs might contain personal details. The logs are used to track down errors or problems in our systems and repair them.
3.6.3. Repositories of Programming Code and Documentation
Legal ground a, explicit permission of person
It is possible for active members to upload code repositories to the version control system of Space Society Twente. These repositories could be a part of a committee, or belong to a personal account. By uploading a repository, explicit permission is given to process the data stored in this repository.
3.6.4. Website
Legal ground f, member administration and communication
The website of Space Society Twente, codenamed Pathfinder, not only holds all information on upcoming events - and thus for that reason is part of our data processing tools -, it also serves as a management system for member administration and member communication. Having this information secured in a single location automates and improves the usage experience from both a member and board member perspective.
3.6.5. G Suite
Legal ground a, explicit permission for active member administration
Although the website of Space Society Twente is sufficient for most purposes, it does not suffice in meeting the expectations active members have of information systems (e.g. to share documents, emails and calendar appointments). As such, G Suite is used to facilitate active members in those activities.
Legal ground f, centralized management value
Space Society Twente highly values the privacy of an individual, however also needs to consider its organizational goals. As having active member documents and emails decentralized and unmanaged would endanger the continuity of functions and working groups, it is therefore reasoned that centralizing management of (active member) resources through G Suite is desirable, and takes precedence over the individual privacy concerns of an active member.
4. Cookies
Usage of the website is possible without a cookie. However, when logged in, the website uses a session cookie, which identifies the user's internet browser through a unique code. This cookie is not used for any other purposes.
5. Changes to Privacy Policy
Space Society Twente is burdened with the protection of an individual’s privacy in accordance with the General Data Protection Ruling. As such, Space Society Twente attempts to deliver maximum transparency on its data collection and processing activities as outlined in this privacy policy.
In a similar fashion, Space Society Twente also continuously desires to improve its services to its members and others. Service changes are often a result of expanding the capabilities of IT systems in use by Space Society Twente, enforcing updated security policies and legislative requirements. As a consequence, these (system) changes could result in modified personal data collection and processing activities.
In its efforts to remain transparent about its data collection and processing activities, Space Society Twente holds the right to update its privacy policy in response to said changes. Individuals affected by these changes will be notified through email, in accordance with section 2.1.2 of this privacy policy.
Individuals have the right to request removal of their personal data from the services offered by Space Society Twente before changes to its privacy policy are made, although certain information cannot be removed due to legal requirements. Individuals will be notified two weeks before such changes are made. Complete removal of personal information automatically results in a termination of membership as specific personal information is required by law as mentioned in the statutes of Space Society Twente.