Specific information for employees and visitors on data protection, regarding the collection of contact and time data during the pandemic for the purpose of tracing contacts in buildings

Data protection information, in accordance with Article 13 of the General Data Protection Regulations (GDPR) regarding the collection of contact data for contact tracing purposes, in order to combat the Corona pandemic within the company’s buildings.

  1. Data Controller

cegecom s.a.
3, rue Jean Piret
L-2350 Luxembourg

Tel.: +352 27 60-1
Fax: +352 27 60-9699
E-Mail: info@artelis.net

  1. Contact details of the Data Protection Officer

artelis s.a.
Data Protection Officer
3, rue Jean Piret
L-2350 Luxembourg
E-Mail: datenschutz@artelis.net

  1. Purpose and legal basis of processing

Data collection, for stays of more than 15 minutes in a building of the artelis group, is carried out for the purpose of tracing the chain of infection and combating the Corona pandemic.

The legal basis for this treatment is Article 6, paragraph 1, point f, of the GDPR, in combination with the general and health regulations on the normal functioning of the Corona of the VSE group, in their most current version.

  1. Categories of personal data

  • Employee data: the collection of contact data (name, first name) as well as the date and registration of “arrival” and “departure” are done via the time pointer;
  • Customer, service provider and employee data without the possibility of check-in via the time pointer: contact information (name, first name, address, telephone number or email address), as well as the date, start and end of the stay are collected.
  1. Recipients of personal data

For the above purposes, contact details are transmitted exclusively to the relevant health authorities at their request. In order to ensure transmission, the Human Resources Department and the Corona Crisis Cell have internal access to the data collected.

  1. Duration of conservation of personal data

Data are deleted by the Officer, one month after the completion of the collection.

  1. Your rights related to the data protection

In case of request, we will gladly inform you if any personal data about you, and which, has been stored by your Officer. In accordance with the legal provisions, you can also assert the following rights: rectification, deletion, processing limitation, data transfer and opposition to processing.

  1. Questions regarding data protection aspects and the right to take action

Please address your questions or complaints to our Data Protection Officer at datenschutz@artelis.net. Without prejudice to another action, you have the right to file a complaint with a supervisory authority. The competent supervisory authority is the National Commission for Data Protection (Commission Nationale pour la Protection des Données, CNPD): 15, boulevard du Jazz, L-4370 Belvaux.

  1. Obligation of data disposal

  • For employees: In order to collaborate in the health protection of all employees, as well as customers and service providers, you are required to provide time recording data.

  • For customers and service providers: you are not required to provide your data. However, without the collection of your contact data, you will not be allowed access to the buildings.