This Privacy Notice contains the information that The European Money Markets Institute is required to provide under the EU General Data Protection Regulation (GDPR) concerning the processing of personal data by The European Money Markets Institute. We may amend this notice from time to time to keep it up to date with legal requirements and the way in which we operate. If we make changes to this notice, we will seek to inform you by notice on our website or email, as applicable.
Personal data we collect
The European Money Markets Institute collects personal data of its employees, applicants, members of governing bodies, customers, service providers, contributors, users of websites, visitors watching content posted by the European Money Markets Institute on social media and its website, members of the press, members of industry associations and members of public and governmental
The categories of personal data that The European Money Markets Institute collects depend on the relationship you have with The European Money Markets Institute. These categories of personal data may include:
Your basic information – such as your names (including name prefix or title, maiden name), gender, date of birth, nationality, marital status, age, national ID number, professional position.
Contact information – such as your address; email address; phone number(s); other contact information.
Financial information needed to perform our payment obligations and rights – such as the information needed to pay our employees, members of governing bodies and service providers and the information needed to invoice our customers or partners.
Information on the use made of our websites - such as statistics on the number of unique visitors (IP address only), page views, time spent on our site: this information is collected via third party cookies. For more information on the use The European Money Markets Institute makes of cookies, please consult our Cookie Policy.
Career Information – Information on your education and work experience and other information contained in your curriculum vitae such as eligibility to work information, languages spoken.
Health data needed to perform our obligations under Belgian employment and social security law – such as medical certificates and workplace accidents of our employees, next of kin/emergency contact information, and
Criminal convictions – information on the criminal record of the employees, members of the Oversight Committee and the Board of Directors.
How do we collect personal data?
Except for information that is required by law, your sharing of personal data with us arises from your will, or a contractual relationship. You will therefore not be subject to adverse consequences if you do not wish to provide us with your personal data. However, please note that if you do not provide certain information, we may not be able to accomplish some or all the purposes outlined in this Privacy Notice, and you may not be able to access certain information, products or systems of The European Money Markets Institute which require the use of such personal data.
If you provide The European Money Markets Institute with personal data of another individual, you are responsible for ensuring that such individual is made aware of the information contained in this Privacy Notice and that an appropriate legal basis is available to share the personal data of that individual with The European Money Markets Institute.
Your personal information might be provided by you directly or by a representative of your company or yourself. Where the personal data is provided by someone else than yourself, you will be informed of the source from which the personal data originates and whether it came from publicly accessible sources in our first communication to you and in any event no later than one month after The European Money Markets Institute has obtained the information.
In some circumstances, personal information may be collected indirectly from monitoring devices or by other means (for example, building and location access control and monitoring systems, closed circuit television (video surveillance - CCTV), telephone logs and recordings, instant message logs and email and internet access logs).
In these circumstances, the personal information may be collected by The European Money Markets Institute or a third-party provider of the relevant service. This type of personal information is generally not accessed on a routine basis, but access is possible and may occur, for instance, in situations where The European Money Markets Institute is investigating possible violations of its policies.
Purposes for which personal data is processed and our legal basis for carrying out the processing & retention
| Purpose | Legal basis | Retention |
|---|---|---|
| The European Money Markets Institute processes personal data as required for the performance of its agreements with its customers, members of the governing bodies and service providers. | Necessary for the performance of a contract to which you are a party. | For the entire duration of the collaboration and 10 years from the end of the collaboration for financial documents and contracts, 5 years for the rest of the documentation. |
| The European Money Markets Institute processes personal data to meet its legal obligations under the Benchmark Regulation and any other applicable laws and to handle complaints (including whistleblowing) and investigations by supervisory authorities, data protection authorities and public authorities. | Necessary for the compliance with a legal obligation The European Money Markets Institute is subject to. | 2 years for whistleblowing and complaints to allow performance of the external audits as prescribed in the Benchmarks Regulation (Art. 7.3), 5 years for the rest of the documentation. |
| The European Money Markets Institute processes personal data for the creation of benchmarks. | Justified based on the Institute’s legal obligation to ensure the proper functioning of its business operations. | During the entire collaboration and 5 years from the end date of the collaboration. |
| The European Money Markets Institute processes personal data relating to its employees to ensure that EMMI meets its legal obligations as an employer. | Necessary for the compliance with a legal obligation The European Money Markets Institute is subject to. | For the duration of the collaboration and 5 years from the end date of the collaboration. |
| The European Money Markets Institute processes personal data of customers in order to monitor and prevent any suspicious or fraudulent activity. | Necessary for the compliance with a legal obligation to ensure the security of the accounts information and to prevent fraudulent activity. | For the duration of the contract and 5 years from the end date of the contract. |
| The European Money Markets Institute processes personal data relating to potential employees for the purpose of the recruitment process. | Justified based on a legal obligation requiring The European Money Markets Institute to process certain information as part of our recruitment exercise (Work permit). It can also be based on the Institute’s legitimate interests for ensuring that we recruit qualified employees. | The European Money Markets Institute will store applicants’ personal data for as long as the open position must be filled. This period is over when a candidate accepts the job offer related to the job opening. When that period is over, the personal data will either be deleted, or be kept in The European Money Markets Institute’s database in case of future job openings, the latter subject to the consent of the candidate. |
| The European Money Markets Institute processes personal data to protect the legal rights and interests of EMMI. | Justified based on the Institute’s legitimate interests for ensuring that The European Money Markets Institute can enforce and defend its legal rights and obligations. | Financial documentation and contracts – 10 years. The remaining documentation: 5 years. |
| The European Money Markets Institute processes personal data relating to the use of its websites to improve the security and functioning of the websites. | Justified based on the Institute’s legitimate interests for ensuring that you receive an excellent user experience and our networks and information are secure. | 5 years. |
| The European Money Markets Institute processes personal data to carry out market surveys. | Justified based on the Institute’s legitimate interests for improving the quality of its products and services. | 5 years. |
| The European Money Markets Institute processes personal data to promote and market its product and services. | Justified based on the Institute’s legitimate interests for improving the quality of its products and services. | 5 years. |
| The European Money Markets Institute processes personal data to communicate practical information to its customers. | Justified based on the performance of the contract between the organisation and its customers for ensuring proper communication throughout the course of the business relationship. | Financial documentation and contracts – 10 years from termination of contracts and 5 years for the remaining of the documentation. |
| The European Money Markets Institute processes personal data to carry out background checks of the members of the Oversight Committee and the Board of Directors. | Necessary for the compliance with a legal obligation The European Money Markets Institute is subject to. | Not retained |
The European Money Markets Institute may retain your personal data during a longer period if it is necessary for legal proceedings, governmental or regulatory requests or investigations, enforcing our agreements and policies or protecting the security and integrity of its products and services.
Criminal convictions certificates are collected for the purposes prescribed by the law – these certificates are not retained on file.
With whom does The European Money Markets Institute share your personal data?
In limited situations, we may transfer personal data to service providers, professional advisors, public and governmental authorities or to interested third parties in connection with a (potential) corporate or commercial transaction.
Some of the recipients to whom The European Money Markets Institute may transfer your personal data may be located outside the European Economic Area (EEA). Such transfers of your personal data will take place in accordance with the appropriate international data transfer mechanisms and standards under GDPR. As such, each processing activity is evaluated to guarantee, prior to its execution, a level of protection in line with the measures dictated by the GDPR.
Similarly, each partner or processor of The European Money Markets Institute is subjected to a thorough investigation of its suitability to meet security requirements regarding the protection of personal data, and enters a processing agreement, regardless of its location.
Security of personal data
The European Money Markets Institute attaches great importance to your right to privacy and the protection of your personal data. The European Money Markets Institute protects your personal data in accordance with applicable laws including the European General Data Protection Regulation (GDPR).
The European Money Markets Institute maintains (partly through service providers) organisational, physical, and technical security arrangements for all the personal data we hold. The European Money Markets Institute has relevant policies, procedures, and processing agreements to maintain these arrangements considering the risks associated with the categories of personal data and the processing it undertakes.
While we implement safeguards designed to protect your information, no security system is impenetrable and due to the inherent nature of the internet, we cannot guarantee the total security of data flows during online transmission or that our IT systems are totally impenetrable and safe from any attempt of intrusion.
Your rights as data subject
Your rights as data subject refer to right to access, correct and delete your personal data. The European Money Markets Institute will respond to your request(s) within a reasonable timeframe and in any event within one month of receipt of the request (unless more time is required in view of the complexity of the request or number of requests received by The European Money Markets Institute).
You are entitled to the following rights:
Right to access - this right entitles you to know whether we hold personal data about you and, if we do, to obtain information on and a copy of that personal data.
Right to correct - this right entitles you to have your personal data corrected if found inaccurate or incomplete.
Right to delete - this right entitles you to request the erasure of your personal data from our systems, including where such personal data would no longer be necessary to achieve the processing purposes it was collected for.
You can also contact us to:
Request the restriction of processing activities - this right entitles you to request that The European Money Markets Institute only processes your personal data in limited circumstances when it is necessary to achieve the presented objective(s)
Object to the processing activities - this right entitles you to request that The European Money Markets Institute no longer processes your personal data. This applies for personal data processing where you have given us your consent.
Exercise your right to data portability - this right entitles you to receive a copy (in a structured, commonly used and machine-readable format) of personal data that you have provided to The European Money Markets Institute or request the latter to transmit such personal data to another data controller.
Contact Us
If you have questions about the processing of your personal data by The European Money Markets Institute or delegated third party providers, or want to exercise the rights set out in the previous section of this Privacy Notice, please send a direct e-mail to: dataprivacy@emmi-benchmarks.eu or fill in the data subject request form available here.
You may also send a request by post at:
Data Privacy Responsible
The European Money Markets Institute
56 Avenue des Arts | 1000 Brussels | Belgium
If you have contacted us and, as a result, have unresolved concerns, you have the right to file a complaint with the Belgian data protection authority (Autorité de protection des données /Gegevensbeschermingsautoriteit) that oversees compliance with the legislation in effect in relation to privacy and the protection of data.
The complaint form can be filled in at the following address using one of the national languages of Belgium (French, Dutch or German).
FR -https://www.autoriteprotectiondonnees.be/citoyen/agir/introduire-une-plainte
Current version: 16/10/2023 – changes relate to integration of retention periods from a stand-alone chapter in this Notice to the table under the "Purposes for which person data is processed and our legal basis for carrying out the processing & retention" section.
Previous version: 30/03/2021 - You can obtain previous versions of our Privacy Notice by contacting us at: dataprivacy@emmi-benchmarks.eu