DATA PROCESSING

Identity of the data controller

The data controller is the Divonne-les-Bains Town Hall, represented by its mayor, Mr Vincent Scattolin.
Registered headquarters’ address: 73 Avenue des Thermes, 01220 Divonne-les-Bains

Persons concerned by the data protection policy
This confidentiality policy is intended for residents, users and partners of Divonne-les-Bains Town Hall who would like further information on the processing of personal data and, more generally, for any person interested in this information.

Definitions

  • Data controller: the natural or legal person, public authority, agency or other body which determines, alone or in collaboration with others, the purposes and means of the processing of personal data
  • Personal data: any information enabling a person to be identified directly or indirectly.
    • Identity details (surname, first name, address, date and place of birth, etc.)
    • Personal data (personal characteristics, lifestyle habits, family situation, etc.)
    • Professional data (CV, professional situation, training)
    • Financial information (income, financial situation, bank card, bank details, etc.)
    • Connection data (IP address, login details, etc.)
    • Location data (geolocation)
    • Cookies, trackers and browsing data (audience, advertising and social network trackers)
    • Sensitive data (religious, political or philosophical opinions, trade union membership, sexual orientation, health data, etc.)
    • Processing: any operation or set of operations relating to personal data, whether or not by automatic means. In general, the collection, recording, organisation, structuring, storage, adaptation, modification, consultation, use, communication, dissemination, deletion or destruction of your personal data constitutes processing of personal data.
    • File: any structured and stable set of personal data accessible according to specific criteria.
    • Recipient: the natural or legal person, public authority, department or any other body receiving personal data, whether a third party or not.
    • Authorised third parties: authorities who are also authorised, in the context of a specific task or the exercise of a right of communication, to ask the Data Controller to communicate personal data to them.
    • Data subject: any person whose data is processed.
    • Processor: the natural or legal person, public authority, department or other body which processes personal data on behalf of the Data Controller.
    • Consent: any freely given, specific, informed and unequivocal expression of will by which the data subject accepts, by a declaration or by a clear positive act, that personal data concerning him or her may be processed.

Your personal data
Your personal data is processed, in accordance with Article 6 of the GDPR (lawfulness of processing), in the following cases:

  • The performance of a contract we have entered into with you, and/or
  • Compliance with a legal obligation, and/or
  • Your consent to the use of your personal data
  • Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the data controller
  • Processing is necessary for the purposes of the legitimate interests pursued by the data controller or by a third party, unless the interests or fundamental rights and freedoms of the data subject which require the protection of personal data prevail, in particular where the data subject is a child. However, this does not apply to processing carried out by public authorities in the performance of their duties.

Your personal data may be processed via our website in the following cases:

  • When you contact us using the contact form.

Information on processing
For each processing of personal data carried out by the Divonne-les-Bains Town Hall, general information on the said processing is provided to the persons concerned. In the interests of transparency, the Divonne-les-Bains Town Hall automatically provides the following information:

  • Subject of the processing
  • Purposes of processing
  • Legal basis for processing
  • Categories of personal data processed (data sources, mandatory nature of data collection, automated decision-making)
  • People concerned
  • Recipient of data
  • Data transfers outside the European Union
  • Retention period for personal data

Why does the Divonne-les-Bains Town Hall collect your data?

Divonne-les-Bains Town Hall collects and uses your data mainly for the purpose of processing your requests for information.

When is your data collected?
When you browse our website, you may enter personal information (in particular when you wish to contact us using the contact form or any other form).
Some of the data listed below is collected automatically as a result of your interactions on the site, and other data is collected using forms filled in by you. The mandatory nature of each item of data is automatically indicated by an asterisk. Your details are processed by Divonne-les-Bains Town Hall and are under no circumstances divulged or sold to other companies for marketing or commercial purposes. Your data will not be transferred to a country outside the European Union or to an international organisation.

When you browse our website:

  • We collect your IP address
  • We collect cookies
  • We collect connection and browsing data

Usefulness and purpose of the processing
The data collected via the contact form enables us to contact you again following one of your requests, to ensure the follow-up of your requests and to guarantee the effectiveness of a service implemented by the Divonne-les-Bains Town Hall.
Your requests and enquiries also enable us to improve the presentation and functionalities of our site in order to offer you the best possible service.
Databases holding personal data are never used without informing you of the purpose of such use. You will be asked for your explicit consent directly on our website.
When you send us personal information relating to an application, this enables us to contact you again if your profile is suitable for the various job offers.

Retention of your data
As a general rule, Divonne-les-Bains Town Hall applies retention periods for all types of archive, depending on the length of time required for administrative purposes.
Apart from the period of administrative usefulness required, Divonne-les-Bains Town Hall sets the retention periods in accordance with and in compliance with article 5.1 e) of the GDPR.
For the sake of precision, the period of administrative usefulness (D.U.A) refers to the time during which the documents are necessary for the activity of the service and/or the citizen to assert their rights. This is a mandatory retention period for documents that is generally expressed in years. Based on criteria of a legal (in particular the limitation periods set by law) or administrative nature, it covers the first two ages of archives (i.e. current archives and intermediate archives)

The conservation of archives therefore responds to three central issues:

  • Day-to-day management of the service (constantly having access to the information needed to run the service smoothly)
  • Justifying rights and obligations (keeping evidence in case of dispute)
  • Safeguarding memory (building up historical material)

The three ages of archives are explained as follows:

  • Current archives: the file is kept alive for the duration of the business and is kept in the office or in its immediate vicinity.
  • Intermediate archives: the file is closed but kept by the producing department, for reasons of activity or legal requirement, in a dedicated archive room nearby.
  • Permanent archives: after sorting and possible elimination, files of historical (and sometimes legal) interest are transferred to the regional, departmental or municipal archives for permanent preservation.

Concerning the final fate of archives:
At the end of the administrative useful life of the documents, and unless this period is extended, the documents may either be kept permanently (documents of historical value) or destroyed. Destruction can only take place once the relevant archivist has given his or her approval for disposal.

Concerning the destruction of archives:
Public archives are inalienable and imprescriptible: they form part of the movable public domain and may not be altered or destroyed without the authorisation of an authorised representative of the State. Civil servants are responsible for the documents they produce or receive, but do not own them. For example, when their A.U.D. expires, public archives are selected to separate documents to be preserved from documents of no historical or scientific interest, which are destined for disposal.

In addition, Divonne-les-Bains Town Hall applies the following retention periods to the processing of personal data relating to your browsing on the website.

Processing

Duration of shelf life applied

Contact form

1 year before deletion


Recipients and transfers of data
Management of the website is outsourced to a specialist service provider (Eolas). It only receives your e-mail address when you subscribe to the newsletter. Divonne-les-Bains Town Hall ensures that the data remains confidential and is not used for any other purpose.

EXERCISING INDIVIDUAL RIGHTS
Exercising individuals rights

The French Data Protection Act of 20 June 2018 on data processing, data files and individual liberties and the GDPR (Articles 12 to 21 of the GDPR) grant you rights relating to your private life. These include the right to information, the right of access, the right to object, the right to restrict processing, the right to rectification and the right to erasure.

  • The right to information
    The privacy policy contains all the information relating to the purposes of the processing that may be carried out, the categories of personal data processed and the recipients or categories of recipients to whom the data is communicated, in order to guarantee your right to information.
  • The right of access
    You can ask the Divonne-les-Bains Town Hall directly whether it holds data about you and also information about how it is processed. You may also request a copy of all your personal data.
  • The right of rectification
    You can ask to modify your personal data at any time.
  • The right to object
    The right to object allows you to object to the processing of your data by Divonne-les-Bains Town Hall, provided that the processing is not necessary for compliance with a legal obligation or the performance of a contractual obligation.
  • The right to restrict processing
    You may request that the future processing of your personal data be restricted under certain conditions: when you dispute the accuracy of personal data, or when you need the data to establish, exercise or defend your legal rights. You may also request that the processing of your data be restricted if the processing is unlawful and you do not wish your data to be deleted.
  • The right to erasure
    You may ask us to delete your personal data, provided that processing is not necessary for the performance of a contractual obligation or for compliance with a legal obligation.
  • Withdrawal of consent
    If you have consented to the processing of your personal data, you may unconditionally withdraw your consent at any time. Information relating to the exercise of these rights is kept for FIVE (5) years from the date of the response from Divonne-les-Bains Town Hall, in accordance with the legal statute of limitations for personal legal actions. Your data relating to the exercise of your rights will then be deleted once this period has expired. In the event of a request to exercise a right, Divonne-les-Bains Town Hall undertakes to respond to you, in accordance with current legislation, within a period of one month, which may be extended by a further two months subject to justification (article 12 of the GDPR).
HOW TO EXERCISE EACH OF THESE RIGHTS

You can exercise each of the rights set out above by providing us with proof of identity.

  • By writing to the following address: Mairie de Divonne-les-Bains 73 Avenue des Thermes, 01220 Divonne-les-Bains

In accordance with the GDPR, Divonne-les-Bains Town Hall reserves the right to request payment of a reasonable fee which takes account of the administrative costs incurred in providing the information, making the communications or taking the measures requested. Divonne-les-Bains Town Hall also reserves the right to refuse to respond to any request that is manifestly unfounded or excessive, informing you of the reasons for the refusal.

In this context and in accordance with the law, we kindly ask to include with your request proof of the information required to identify you (surname, first name, address, email address) or the persons concerned, as well as any other information required to confirm their identity.

These identification details will only be kept for as long as it takes to process our response, and will then be deleted.

Divonne-les-Bains Town Hall informs you that you have the right to contact the Commission nationale de l'informatique et des libertés (CNIL), and to lodge a complaint at this address: www.cnil.fr

In the event of a breach of the regulations applicable to the protection of personal data, the persons concerned also have the right to lodge a complaint with the Commission nationale de l'informatique et des libertés on French territory (3 place de Fontenoy - TSA 80715 - 75334 Paris cedex 07; tel: +33 (0)1 53 73 22 22), without prejudice to any other administrative or legal remedy.

Updated on 22 November 2022.