Wednesday, 26. February 2020
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    Mamer school doesn’t care about personal data protection

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    Director of European school Luxembourg 2 Mr Emmanuel de Tournemire decided to pay for another survey. This time it is about school transport. Again they care only about gathering data, spending money and pretending they are actually doing something important. They have no idea how will they use this data or if they will use it at all. Exactly like with previous surveys. Couple of years ago Mr de Tournemire paid PriceWaterhouseCoopers 20.000€ for a satisfaction survey.

    It will be hard to collect statistically relevant data because:

    • This survey is a cookie based so each participant can reply multiple time is (s)he deletes cookie, browsing history or change device. Survey should prevent this kind of behaviour.
    • Survey should avoid showing illogical answers. For example showing car driver as a mode of transport for children younger than 16 years old it is redicoulous since it is obvious they can’t legally drive car.

    And again they completely ignore personal data protection. This is the email I sent to the survey organiser, school director Mr Emmanuel de Tournemire and APEEEL2 president Ms Sandra Vella.

    ________________________________

    Dear Mr Sprumont

    I received invitation for survey that you prepared in collaboration with European school Luxembourg 2 and APEEEL2.

    Since you are collecting personal data I’m missing important information about personal data protection. According to the European directive (EC) No 45/2001 and Luxembourgish 2002 Act., modified in 2007, every data collector should provide the following data to the data subject at the collection of the personal data:

    • The identity of the data controller and its representative, if any
    • The purpose(s) of the data processing.
    • The data or categories of data that are to be processed. The recipients or categories of recipients to whom such data can be disclosed.
    • Their rights to access and rectify their data and oppose the data processing, and in this case the consequences of the decision.
    • Any information that may be deemed necessary to ensure fair data processing, given the circumstances under which the data are collected.

    Data subjects must, in addition, be informed about automated decision-making processes. The information must be transmitted, at the latest, at the time the personal data is:

    • Collected, if collected directly from the data subjects.
    • Recorded or disclosed for the first time, if not collected directly from the data subjects.

    I would kindly ask you to address this issue.

    I do hope there will be some reaction.


    UPDATE: 15.05.2016, 08.22

    Mr Francesco Viti, head of the mobiLab group, which has set up the transport survey, kindly provided information I requested.

    •         The identity of the data controller and its representative, if any

    The data is collected and processed at the University of Luxembourg (UL), which is a non-profit legal entity where control of the data is guaranteed by the UL Ethical Review Panel.

    •         The purpose(s) of the data processing.

    As explained in the first page of the survey, and in the invitation email, the data collected is anonymised, and results are all processed, analysed and presented in an aggregated form. The purpose, as stated, is to have an understanding of the traffic and mobility issues currently affecting the School accessibility, and to provide concrete recommendations for improvements of both car and collective transport users to the responsible stakeholders.

    •         The data or categories of data that are to be processed. The recipients or categories of recipients to whom such data can be disclosed.

    All data collected is used solely for the purpose stated above. Only a restricted number of UL researchers involved in the initiative (Mr. Sprumont, Miss Scheffer and myself), the School Director Mr. de Tournemire, the President of APEEEL2 (Mrs. Vella) and the Transport project manager of the School (Mr. Tyrrel) may have access to the raw data.

    •         Their rights to access and rectify their data and oppose the data processing, and in this case the consequences of the decision.

    Being anonymised, the data cannot be rectified once submitted, unfortunately. On the other hand, the respondents can modify their data at any time before finalising the survey.

    •         Any information that may be deemed necessary to ensure fair data processing, given the circumstances under which the data are collected.

    We tried with the above responses to have provided the necessary information. We will make sure these responses are included in the survey, and we will specifically mention the EU directive and Luxembourgish law below indicated.

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