PRIVACY POLICY FOR THE ONLINE TRAINING PLATFORM TEMBO

Last Update: December 2022

 

In compliance with the personal data protection regulation in force, you are hereby informed of the following:

 

DATA CONTROLLER

MÉDICOS SIN FRONTERAS ESPAÑA (hereinafter, “MSF”), with registered office at C/ Zamora 54, 08005 – Barcelona (Spain).

 

YOUR RIGHTS

You may exercise your rights of access, rectification, erasure and portability, restriction and/or right to object to the processing, at the postal address indicated in the section “DATA CONTROLLER” and at the following email address: DPO.BCN@MSF.ORG.

Should you consider that the processing of your personal data infringes the data protection regulation or your rights, you may submit a complaint:

 

• To our Data Protection Officer, via the postal and electronic addresses indicated in the sections “DATA CONTROLLER” and “DATA PROTECTION OFFICER”.
• To the Spanish Data Protection Agency, via its website (www.aepd.es) or its postal address: c/ Jorge Juan, n.º 6, CP: 28001, Madrid.

 

DATA PROTECTION OFFICER

You may contact our Data Protection Officer at MSF SPAIN’s postal address or at the following e-mail address DPO.BCN@MSF.ORG

HOW WE OBTAIN YOUR PERSONAL DATA

We generally obtain your personal data from you when you voluntarily provide them to us by filling out the registration form available on the platform.

We may also obtain your personal data (identification data and, in some cases, your professional contact data) from the DOCTORS WITHOUT BORDERS section that has hired you.

 

WHAT PERSONAL DATA DO WE PROCESS, FOR WHAT PURPOSES, AND FOR WHICH REASONS WE ARE AUTHORIZED TO PROCESS THEM

 

IF YOU ARE DOCTORS WITHOUT BORDERS STAFF THAT IS CURRENTLY EMPLOYED:

 

TYPE OF DATA

 

MSF SPAIN will process the following personal data:

• Initial Data: the data that you provide when requesting to register for the training services, or, where applicable, the data that your section provides to us in order to register you for such services. Among these data we may ask you for the Gender data, which you are free to answer or indicate that you prefer not to do so.

• Additional Data: We will also process the data concerning you that arise from providing the training services, your interactions with the platform, and your interactions with other users of the platform.

 

PURPOSES

MSF SPAIN will process your personal data to: (1) manage your participation on the training platform; (2) provide the training services; and (3) follow up on such trainings.

Data about your gender will only be used for the purpose of determining whether everyone has equal access to Tembo,and help us to achieve better learning opportunities for all ranges of people identities.

 

MSF SPAIN will process your personal data to comply with its legal obligations.

LEGAL GROUNDS

The processing of your personal data is necessary to comply with the obligations arising from the contractual relationship between you and the DOCTORS WITHOUT BORDERS section that has hired you.

Data about your gender will be processed only on the basis of your free and explicit consent. You may indicate that you do not wish to respond if you deem it appropriate.

The processing of your personal data is necessary to comply with MSF SPAIN’s legal obligations.

IF YOU ARE A VALIDATED APPLICANT OR DOCTOR WITHOUT BORDER STAFF IN BETWEEN ASSIGNMENTS

MSF SPAIN will process the following personal data:

TYPE OF DATA

• Initial Data: the data that you provide when requesting to register for the training services, or, where applicable, the data that your section provides to us in order to register you for such services. Among these data we may ask you for the Gender data, which you are free to answer or indicate that you prefer not to do so.

Additional Data: We will also process the data concerning you that arise from providing the training services, your interactions with the platform, and your interactions with other users of the platform.

PURPOSES

MSF SPAIN will process your personal data to: (1) manage your participation on the training platform; (2) provide the training services; and (3) follow up on such trainings.

Data about your gender will only be used for the purpose of determining whether everyone has equal access to Tembo and help us to achieve better learning opportunities for all ranges of people identities.

MSF SPAIN will process your personal data to comply with its legal obligations.

LEGAL GROUNDS

The processing of your personal data is necessary to comply with the obligations arising from the contractual relationship between you and the DOCTORS WITHOUT BORDERS section that has hired you.

Data about your gender will be processed only on the basis of your free and explicit consent. You may indicate that you do not wish to respond if you

The processing of your personal data is necessary to comply with MSF SPAIN’s legal obligations.

 

IF YOU ARE ANOTHER TYPE OF INDIVIDUAL

 

TYPE OF DATA

MSF SPAIN will process the following personal data:

• Initial Data: the data that you provide when requesting to register for the training services, or, where applicable, the data that your section provides to us in order to register you for such services. Among these data we may ask you for the Gender data, which you are free to answer or indicate that you prefer not to do so.
• Additional Data: We will also process the data concerning you that arise from providing the training services, your interactions with the platform, and your interactions with other users of the platform.

 

PURPOSES

MSF SPAIN will process your personal data to: (1) manage your participation on the training platform; (2) provide the training services that you request and (3) follow up on such trainings.

Data about your gender will only be used for the purpose of determining whether everyone has equal access to Tembo, and help us to achieve better learning opportunities for all ranges of people identities

MSF SPAIN will process your personal data to comply with its legal obligations.

 

LEGAL GROUNDS

The processing of your personal data is necessary to comply with the obligations arising from the contractual relationship between you and the DOCTORS WITHOUT BORDERS section that has hired you.

Data about your gender will be processed only on the basis of your free and explicit consent. You may indicate that you do not wish to respond if you deem it appropriate.

The processing of your personal data is necessary to comply with MSF SPAIN’s legal obligations.

 

 

UPDATING YOUR PERSONAL DATA

MSF wants to keep your personal data up to date in order to guarantee the confidentiality and security of data access by our staff on the platform. For this reason, it is important that you keep your personal data updated, in particular, those data related to your status, mission and geographical location. We recommend that you update your data at least every semester.

 

MSF will not be responsible for the lack of updating of your data. Nevertheless, we will send you a reminder to update your data, if necessary, approximately every six months.

 

RECIPIENTS

Your data may be disclosed to the recipients listed below, for the reasons explained below. Your data will only be processed by those persons or entities that, depending on the professional relationship they have established with MSF SPAIN, have the necessary roles and permissions to do so.

 

In this way, the recipients to whom the personal data are communicated will only have access to and be able to view the data that is strictly necessary to carry out the professional functions attributed to them.

 

The recipients to whom we refer are explained below:

• MSF staff responsible for the management and monitoring of training material in Tembo: e.g., administrators, course creators and designers, tutors, etc., in order to ensure proper management and monitoring of courses.
• MSF staff responsible for the management and development of MSF staff: such as Human Resources Coordinators, Development Managers, Pool managers, among others; to detect development opportunities and suggest support plans, as well as to promote training spaces for staff assigned to a given project.
• Public Administrations: for compliance with the legal obligations to which MSF SPAIN is bound due to its activity.
• Courts and Tribunals: in the cases provided by law.
• Law enforcement agencies: when our organization is required to provide information in compliance with a legal obligation.
• Providers that need access to your data in order to provide services that MSF SPAIN has engaged to those providers, and with whom MSF SPAIN has signed confidentiality and data processing agreements as required by the regulations in order to protect your privacy.

 

Should MSF SPAIN disclose your personal data to other recipients in the future, it will duly inform you.

 

INTERNATIONAL DATA TRANSFERS

MSF SPAIN has engaged the services of providers located in countries that do not have regulations equivalent to the European (“Third Countries”). These providers have signed, with MSF SPAIN, the confidentiality and data processing contracts required by the regulations for providers located in Third Countries, applying the guarantees and safeguards necessary to preserve your privacy. Such guarantees and safeguards may consist in adequacy decisions of the European Commission and/or standard contractual clauses approved by the European Commission, and which contain additional safeguards to preserve the European Union's essential privacy safeguards.

 

In addition, some of the Recipients listed above may also be located outside the European Economic Area. For the transfer and access by such recipients to your personal data, we ensure that any of the many safeguards for the international transfer of data, such as adequacy decisions, appropriate safeguards (e.g. binding corporate rules, standard contractual clauses or codes of conduct) or exceptions for specific situations apply.

 

For more information on the guarantees regarding international data transfers, you may contact our Data Protection Officer at the postal and electronic addresses mentioned in this Privacy Policy.

 

AUTOMATED DECISION-MAKING

MSF SPAIN does not adopt automated decision-making that may significantly affect you. All the decision-making processes are performed with human intervention and for the purposes mentioned above.

 

FOR HOW LONG DO WE STORE YOUR PERSONAL DATA

Your personal data will be kept for as long as your relationship with MSF SPAIN is maintained, that is, as long as you are registered on the Tembo platform and, after the termination of this relationship for any reason, during the applicable legal limitation periods. After the termination of the relationship, your data will be processed for the sole purpose of accrediting compliance with the legal, tax or contractual obligations of MSF SPAIN.

 

Once said periods have ended, your data will be deleted or, alternatively, anonymized.