WorldSkills Namibia is subject to the Namibian Data Protection Regulation (2016) for the protection of natural persons with regard to the processing of personal data and on the free movement of such data. WorldSkills Namibia will apply the principles of this regulation (subject to other jurisdiction’s data sovereignty laws) to its treatment of personal data belonging to individuals regardless of their citizenship.
These definitions are taken from the European Union General Data Protection Regulation (2016).
1.1.1. Personal data
Personal data means any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
Processing means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.
3. Collecting personal information
The collection of an individual’s personal data shall be adequate, relevant, and limited to what is deemed necessary for processing purposes. This is the principle of data minimization.
Personal data is collected for one or more of the following purposes:
- To record the details of job applicants, officers, membership, delegates, or competition personnel as specified in the official documents of WorldSkills Namibia: Constitution, Standing Orders, Code of Ethics and Conduct, and Competition Rules, or any other committee, working group, or body within the organization.
- To register and determine validity to participate at a WorldSkills event.
- To fulfil a contract that WorldSkills Namibia has entered into with an individual or with an entity that the individual represents.
- To initiate and complete commercial transactions with an individual, or the entity that the individual represents, for the purchase of products and/or services.
- To manage any communication between an individual and WorldSkills.
3.1. Use of the WordSkills Namibia website
In order to ensure that each visitor to any WorldSkills Namibia website can use and navigate the site effectively, the following is collected:
- information about a visitor’s computer including IP address, geographical location, browser type and version, and operating system; and
- information about visits to and use of the website including the referral source, length of visit, page views, and website navigation paths.
WorldSkills Namibia handles the personal data it receives through the website with care. When an individual visits the website for the first time, the web server sends a cookie to the individual’s device on behalf of WorldSkills Namibia for statistical purposes. A cookie is also used to maintain a logged in session as an individual uses the WorldSkills Namibia website. If an individual chooses to not make use of these features, they can set their Internet browser to block cookies. If they accept cookies, they will remain on the individual’s device for up to five years unless deleted.
4. Lawfulness of processing
WorldSkills Namibia has reviewed the purposes of processing activities and selected the most appropriate lawful basis for each activity.
4.1. Lawful Bases
Collection and processing of an individual’s personal data is lawful only if and to the extent that at least one of the following legal bases applies.
4.1.1. Legitimate interest
As a Technical Vocational Education and Training (TVET) membership organization, WorldSkills Namibia has the legal basis to collect and use the minimum required data of an individual associated with WorldSkills Namibia for the purposes of managing (prospective) office holders, membership, delegates, or competition or event personnel.
4.1.2. Contractual performance
Where processing is necessary for the performance of a contract to which an individual is party.
An individual has given consent to the collection and use of personal information. Such consent is optional and can be withdrawn at any time.
4.1.4. Legal obligation
Processing of personal data that is necessary for compliance with a legal obligation to which WorldSkills Namibia is subject.
5. Vital interest
Processing of personal data that is necessary to protect the vital interests of an individual.
6. Using personal information
An individual’s personal data will only ever be used for the purposes for which it is collected. Should the purposes change, WorldSkills Namibia will contact the individual and inform them based in the lawfulness of processing, determined for the new process.
An individual’s personal data will not be transferred to any third party or any other third party’s direct marketing.
An individual’s personal data must be accurate and, where necessary, kept up to date; every reasonable step will be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed according to this policy, are erased or rectified without delay.
7. Disclosing personal information
WorldSkills Namibia may disclose an individual’s personal information to any of its office holders, members, delegates, competition or event personnel, Competition Organizers, employees, contractors, advisers, vendors, agents, service providers, suppliers, or subcontractors as reasonably necessary for the purposes set out in this policy.
WorldSkills Namibia may disclose an individual’s personal information:
- to the extent that WorldSkills Namibia is required to do so by law;
- in connection with any ongoing or prospective legal proceedings;
- in order to establish, exercise, or defend WorldSkills Namibia’s legal rights; and
- to any person who WorldSkills Namibia reasonably believes may apply to a court or other competent authority for disclosure of that personal information where, in WorldSkills Namibia’s
reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.
Except as provided in this policy, WorldSkills Namibia will not provide an individual’s personal information to third parties.
7.1. Our vendors and service providers
WorldSkills Namibia relies on a network of professional vendors and service providers who are working on WorldSkills Namibia’s behalf and help operate, develop, secure, promote, and measure WorldSkills Namibia’s services.
Services provided by these partners include:
- Infrastructure and general IT services;
- Platform development services;
- Hosting services;
- Customer relationship management and other communication services;
- Analytics and measurement services;
- Email communications; and
- Third party web and social media services.
7.2. Events related services
If an individual uses WorldSkills Namibia’s systems to request certain services, for instance registration or accreditation to attend the National Skills Competition or other events organized by WorldSkills Namibia, or for booking accommodation in relation to these events, the provision of the services requested by an individual may require WorldSkills Namibia to share personal information with third parties (e.g. travel or accommodation providers, Competition Organizers, or governmental agencies). WorldSkills Namibia will specify in the relevant Terms of Service the categories of third parties with whom an individual’s personal information may have to be shared and other conditions applicable to such sharing of information in relation to the services requested.
8. International data transfers
Information that WorldSkills Namibia collects may be stored, processed in, and transferred between other WorldSkills member countries, regions in order to enable WorldSkills Namibia to use the information in accordance with this policy.
Information collected in order to participate at a WorldSkills event will be transferred to the country or region where the event is taking place for the purposes of managing an individual’s participation at that event.
Individuals are reminded that data collected in different jurisdictions is subject to data sovereignty legislation within that jurisdiction. There may be instances where legislation in one jurisdiction is in conflict with the legislation of another. WorldSkills Namibia will determine the best course of action that supports the individual’s rights. In some cases that may mean that an individual may have to submit data already collected and processed in a system under one jurisdiction into another system that is subject to the legislation of another jurisdiction.
9. Retaining personal information
An individual’s personal information that WorldSkills Namibia processes for any purpose shall not be kept for longer than is necessary for that purpose.
WorldSkills International will retain documents (including electronic documents) containing personal data:
- To the extent that WorldSkills Namibia is required to do so by law;
- If WorldSkills Namibia believes that the documents may be relevant to any ongoing or prospective legal proceedings; and
- in order to establish, exercise, or defend WorldSkills International’s legal rights.
10. Security of personal information
WorldSkills Namibia will take all reasonable technical and organizational precautions to prevent the loss, misuse, or alteration of an individual’s personal information.
WorldSkills Namibia does not process or enter into electronic financial transactions no its website.
An individual is responsible for keeping the login details including password used for accessing WorldSkills Namibia’s website and applications confidential; WorldSkills Namibia will not ask an individual for their password (except when logging in to the website or other WorldSkills applications).
WorldSkills Namibia does not have any control over what happens between an individual’s device and the boundary of WorldSkills Namibia’s information infrastructure. Transmission of information over the Internet is inherently insecure, and WorldSkills Namibia cannot guarantee the security of data sent over the Internet. An individual should be aware of the many information security risks that exist and take appropriate steps to safeguard their own information. WorldSkills Namibia accepts no liability in respect of breaches that occur beyond its sphere of control.
As a data subject whose personal information WorldSkills Namibia holds, an individual has certain rights.
An individual’s rights are as follows:
11.1. The right to be informed
11.2. The right of access
An individual may request a copy of the personal data held about them free of charge. Once WorldSkills Namibia has verified an individual’s identity and, if relevant, the authority of any third-party requestor, WorldSkills Namibia will provide access to the personal data held about the individual as well as the following information:
- The purposes of the processing;
- The categories of personal data concerned;
- the recipients to whom the personal data has been disclosed;
- The retention period or envisioned retention period for that personal data; and
- When personal data has been collected from a third party, the source of the personal data.
If there are exceptional circumstances that mean WorldSkills Namibia can refuse to provide the information, WorldSkills Namibia will explain them. If requests are frivolous or vexatious, WorldSkills Namibia reserves the right to refuse them. If answering requests is likely to require additional time or unreasonable expense (which an individual may have to meet), WorldSkills Namibia will inform the individual.
11.3. The right to rectification
When an individual believes that WorldSkills Namibia holds inaccurate or incomplete personal information, the individual may exercise their right to correct or complete this data. This may be used with the right to restrict processing to make sure that incorrect/incomplete information is not processed until it is corrected.
11.4. The right to erasure (the “right to be forgotten”)
Where no overriding legal basis or legitimate reason continues to exist for processing personal data, an individual may request that WorldSkills Namibia deletes the personal data. This includes personal data that may have been unlawfully processed. WorldSkills Namibia will take all reasonable steps to ensure erasure.
Legitimate reasons for retaining data include participation at a National or WorldSkills Competition, where name, country, skill, position, and award (if applicable) will be retained for historical purposes. Any other data may be removed at an individual’s request.
11.5. The right to restrict processing
An individual may ask WorldSkills Namibia to stop processing their personal data. WorldSkills Namibia will still hold the data but will not process it any further. This right is an alternative to the right to erasure. If one of the following conditions applies an individual may exercise the right to restrict processing:
- The accuracy of the personal data is contested;
- Processing of the personal data is unlawful;
- WorldSkills Namibia no longer needs the personal data for processing but the personal data is required for part of a legal process; and
- The right to object has been exercised and processing is restricted pending a decision on the status of the processing.
11.6. The right to data portability
An individual may request their set of personal data be transferred to another controller or processor, provided in a commonly used and machine-readable format provided that such format is available. This right is only available if the original processing was on the basis of consent, the processing is by automated means, and if the processing is based on the fulfilment of a contractual obligation.
11.7. The right to object
An individual has the right to object to WorldSkills Namibia processing of their data where:
- processing is based on legitimate interest(s);
- processing is for the purpose of direct marketing;
- processing is for the purposes of scientific or historic research; and
- processing involves automated decision-making and profiling.