Copyright © 2019 Belnet, Simon Bolivar Avenue 30, 1000 Brussels, Belgium, tel. 02/790.33.33, fax 02/790.33.34
I. GUESTROAM ACCESS: request & account
Belnet facilitates the management of guest accounts for the institutions that have already joined the govroam / eduroam services. Those institutions will enrol guest users as temporary eduroam/govroam users via a web interface provided by Belnet.
Three different actors are distinguished here, each with their own specific role.
a) The visitor who fills in a guestroam request to receive a temporary guestroam account.
b) Belnet who has the role of guestroam identity provider to give the visitor the option to request a temporary guest account and to receive this account from an organisation that is a member of the govroam/eduroam service that he or she wishes to visit.
c) The organisation to be visited is responsible itself for validating the guestroam account so that the visitor can use the roaming free of charge (hereinafter referred to as Visiting resource roaming provider).
The mutual rights and obligations between Belnet and the Visiting resource roaming provider have been laid down in an agreement for access to Belnet’s eduroam/govroam service.
This policy lays down the mutual rights and obligations between the visitor and Belnet.
II. PROCESSING OF PERSONAL DATA OF THE GUESTROAM VISITOR
When providing the guestroam service, Belnet acts as the controller of the personal data of the visitor as indicated below.
Belnet is a public department under separate management, founded within the Belgian Federal Science Policy Office and established at Simon Bolivar Avenue 30, 1000 Brussels, Belgium, tel. 02/790.33.33, fax 02/790.33.34.
Official for data protection
The official for data protection at Belnet is the contact person for all questions related to the processing of personal data in general, and this processing policy for the personal data in particular. The official for data protection can be contacted at firstname.lastname@example.org.
Processing purposes and legal basis for processing
Finality of the processing of personal data
The above personal data are only collected and processed for the purpose of providing the guest account for eduroam/govroam requested by the user.
Legal basis for processing of personal data
When filling in the guestroam request we ask the visitor to fill in a number of personal data. These personal data are necessary to provide the guestroam service.
Categories of personal data
personal username and a code (password)
mobile telephone number
Recipients of personal data
Belnet limits access to personal data to employees, subprocessors and recipients of personal data to the minimum required. Belnet only provides access to employees for whom access to the personal data is required.
Access to personal data stated in the guestroam request is restricted to authorized Belnet staff for this purpose.
The disclosure of personal data is limited to the persons of the visiting organisation registered and authorised for this purpose at Belnet and authorised persons from the visited institution.
Period of saving
The personal data are kept for 1 month from the expiry of the end date of the temporary guestroam account.
Rights of the data subject and exercising the rights
Rights of the data subject
The data subject has the right to send a request to Belnet to view, change or erase personal data or to restrict its processing. The data subject also has the right to object to processing and the right to transfer the data.
Exercising rights by the data subject
Data subjects can exercise the above rights by mail sent to email@example.com.
In accordance with the stipulations in the regulation, Belnet will act upon this request no later than within a month of receipt of the request. The period can be extended by two months if required depending on the complexity of the request and the number of requests.
Withdrawal of permission
When the data subject has given permission for the processing of his/her personal data for one or more processing purposes, the data subject can withdraw his/her permission at any time. Withdrawal does not prejudice the legality of processing based on the permission before its withdrawal.
Submission of a complaint by the data subject
To submit a complaint, the data subject can send a request to the Data Protection Authority at the follow address:
No automated individual decision-making
No automated individual decision-making takes place with the processing of these personal data by Belnet.
Belnet binds itself to take appropriate technical and organisational measures with the collection and processing of personal data, and this in accordance with the principles of the General Data Protection Regulation to guarantee a security level commensurate with the risk.
With the assessment of the appropriate security level for processing personal data, account is taken of the processing risks such as the consequence of the destruction, the loss, the changing of or unlawful access to sent and saved processed personal data, that either accidentally or wrongfully can take place.
III. ACCEPTABLE USE POLICY
Responsibility for the identification data
The user who submits a guestroam request and receives a guestroam account is responsible for the use of his/her guestroam identification data.
The user who receives a guestroam account must comply with the regulations for acceptable use of the Visiting resource roaming provider.
The user who receives a guestroam account should, if he/she suspects that his/her eduroam/govroam identification data have been misused, inform Belnet and the Visiting resource roaming provider of this (risk of) misuse immediately.
Logs that are kept
Belnet also collects information in log files. The logs that are kept only contain traffic data. This information is used by Belnet for internal purposes and traffic analysis. The logs are kept for 1 month.
Belgian law applies to disputes relating to (non)compliance with this guestroam access policy. The courts of Brussels have jurisdiction.
V. CHANGES TO THE GUESTROAM POLICY