PRIVACY POLICY
(FOR THE DURATION OF COVID-19 PANDEMIC)
This data management information (hereinafter the Information) aims to provide adequate information on the data management, data management principles and rules in force in an epidemiological situation by the Hungarian Anti-Doping Group Public Limited Company (headquarters: 1146 Budapest, Istvámezei út 2 / C, 7th floor 99 .; hereinafter referred to as Controller or HUNADO).
- Controller
Company name of the Controller: Hungarian Antidoping Group Public Nonprofit Ltd.
Registered office of Controller: 1146 Budapest, Istvánmezei út 2/C, 7th floor 99.
Phone number of Controller: +36 1 273 1715
Name of Data Protection Officer: Dr. Szabó Gergely Balázs
Email of Data Protection Officer: dpo@antidopping.hu
- HUNADO has its current Privacy Policy on its website(www.antidopping.hu) in electronic form.
- Purpose and legal basis of Data Management
- Purpose of Data Processing: In accordance with the rules of the European General Data Protection Regulation (GDPR), the protection of the integrity of persons involved in doping controls, in particular athletes (including the data subject himself) and HUNADO doping control officers, during doping controls. The ultimate goal of data management is to prevent the spread of the COVID-19 pandemic.
- The legal basis of Data Processing: (i) the processing of personal data is necessary for purposes of the legitimate interests of HUNADO and third parties [Article 6 (1) (f) GDPR], in the case of Hungarian-resident athletes and persons participating in their control, the data processing is in the public interest [Article 6 (1) GDPR ) (e)], (ii) the processing of health data is carried out with the consent of the data subject [Article 9 (2) (a) GDPR] and in the public interest in the area of public health, such protecting against serious cross-border threats to health [GDPR Article 9 (2) (i)].
- Data Management in the public interest
The interest in carrying out an anti-doping activity is in the public interest, as follows:
- Hungary in accordance with 99/2007. (V. 8.) promulgated the International Convention Against Doping in Sport, adopted by the General Assembly of the United Nations Educational, Scientific and Cultural Organization (UNESCO) in 2005 (hereinafter referred to as the "Convention"). Under Article 3 of the Convention, States Parties, including
Hungary, are required to adopt measures in accordance with the principles of the World Anti-Doping Code adopted by the World Anti-Doping Agency (WADA) on 5 March 2003 in Copenhagen.
- Act I of 2004 on Sport (hereinafter: the “Sport Act”) classifies the protection of the purity of sport and the reduction of prohibited performance enhancements as a substantial public interest, on the basis of which HUNADO is entitled to process personal data, including health, genetic and biometric data.
- In the field of anti-doping, the management and transfer of data, in view of the large number of data subjects and cross-border global cooperation, is also mentioned in the current Data Protection Regulation (GDPR) itself in the context of the "public interest", with the aim of restricting and/or eliminating the use of doping substances in sport.
- Enforcement of legitimate interest as a legal basis
During an epidemic, it is in the fundamental interest of both the athlete / sports professionals and, more broadly, society as a whole, to prevent a person suspected of being infected from participating in doping control, thus preventing the spread of the epidemic.
Doping control during an epidemic period, as it is necessarily carried out from human body fluids and involving personal contact, may be performed safely if the suspicion of infection in the persons concerned can be ruled out. The suspicion of infection may be realized by an epidemiological risk assessment of the person concerned.
At the same time, it is a fundamental right and interest of athletes and sports professionals involved in data processing that their rights to the protection of their personal data are not violated.
Considering that,
- all athletes, sports professionals, sports organizations, States Parties and their citizens who have acceded to the Convention have a universal legal interest in the enforcement of anti-doping rules;
- these doping controls can only be carried out without epidemiological risk (infection) and with absolute protection of the values of human life and health (and thus the data subjects themselves will benefit from the data management associated with risk assessment),
the legitimate interests expressed in this section take precedence over the interest of the Athlete / Sports Professional / other persons involved in doping control that their personal data are not to be processed by HUNADO.
- The public interest in public health and the consent of the data subject as a legal basis
The public interest in public health, such as the protection against serious cross-border threats to health, is the legal basis for data processing also referred to in the GDPR [Article 9
(2) (i) GDPR]. This legal basis may be based on the relevant national or EU law.
As data processing can take place on several legal bases at the same time, in the absence of uniform national and EU legislation, we also ask for your personal, voluntary consent, based on this prior information, to the health data needed to identify the epidemiological risk.
- How long is your personal data stored?
Your data will be deleted after the 30th day following sampling.
- What is the aim of Data Processing and which personal data is needed to be given?
| The personal data concerned |
The specific purpose of processing |
Can the data be transferred? |
Legal basis |
| Name, address, field of sport |
your identification |
If applicable, yes, see point 9. |
substantial public interest / legitimate interest |
| Covid-19 screening history |
to rule out your potential infection |
public interest affiliated with public health / consent |
| In the absence of 2 negative PCR tests within 5 days and 48 hours apart: |
| Health information |
to rule out your potential infection |
If applicable, yes, see point 9. |
public interest affiliated with public health / consent |
| Contact data with a person infected with Covid-19 |
| Data concerning stay abroad[1] |
- Where will the data be stored?
In the European Union, at the headquarters and premises of HUNADO in Budapest.
- Who is entitled to access the data?
HUNADO's test manager and medical experts are entitled to access your data.
- Can the personal data you provide be transferred to a third party?
To a narrow circle, if HUNADO is obliged to do so at the request of an official (especially a health/epidemiological authority).
If HUNADO is obliged to transfer the data it handles under the World Anti-Doping Code, your personal data will only be transferred to the anti-doping organization competent for you (in particular: the Sports Federation and WADA) or to the acting laboratory, expert or panel of experts (Athlete Passport Management Units) or to the Sample Collection Authority involved by HUNADO in order to achieve the objectives of the World Anti-Doping Code. These organizations are similarly required to secure the processing of personal data under contract.
- What rights do you have as the owner of personal data?
We would like to inform you that in connection with the data processing performed by HUNADO, you have the following rights:
- request access to personal data on you;
- receive your personal data in a machine-readable format or to transfer this data to another data controller;
- receive feedback from the data controller as to whether the processing of your personal data is in progress.
If you become aware of the illegal handling of your data, please notify us by sending an email to dpo@antidopping.hu
- What are the remedies available to you?
If you become aware of the illegal handling of your data, please notify us by sending an email to dpo@antidopping.hu
If you find that HUNADO is in breach of data protection law with regard to the processing of your personal data, you may lodge an appeal with the territorially competent court or the National Data Protection and Freedom of Information Authority in order to protect your rights.
Contact details of the National Authority for Data Protection and Freedom of Information:
Nemzeti Adatvédelmi és Információszabadság Hatóság
Headquarters: 1125 Budapest, Szilágyi Erzsébet fasor 22 / C.
Phone: +36(1)391-1400
Fax: +36(1)391-1410
Electronic contact: ugyfelszolgalat@naih.hu
Website: http://naih.hu
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