Posted on 14 January 2021

Requirement for Board members to agree to GDPR policies of the APEEE


Dear Class representatives,

A discussion has been prompted by a group of class representatives as to whether APEEE Board members can be required to sign a GDPR Confidentiality agreement. The APEEE Board has decided that all Board members should sign such an agreement because the APEEE deals with a considerable amount of personal information of its members, such as complaints against the school, issues to do with bullying, requests for learning support, requests for financial assistance etc which is both extremely sensitive. The APEEE is therefore defined as a data controller and data processor under GDPR and so is required under Belgian (and EU) law to establish measures for how this information will be managed and protected.

GDPR legislation applies to all organisations operating in the EU that handle personal information. No exceptions are made for volunteer organisations such as the APEEE. For staff, this is managed by their employment conditions; for Board members, who receive and process personal information, through the GDPR Confidentiality document. The APEEE Board is the entity legally responsible for setting such policies because it is the entity legally accountable for ensuring compliance with this legislation.

Please read the attachment (Please click on this link) prepared by the GDPR specialist at the APEEE’s lawyers, which explains these obligations and the potential consequences, in terms of fines for the APEEE and individual liabilities for Board members if the APEEE does not have policies in place to enforce GDPR compliance.

Board members are also requested to treat as confidential information that the APEEE is given which is provided on the basis that the APEEE keeps it confidential. This includes all preparatory documents for Board of Governors and the important meetings of the European Schools’ system, as well as certain documents for the Woluwe School Admin Board meetings which are of a sensitive nature. This is only a small proportion of the documents the APEEE deals with, but failure to respect the confidentiality requested by the Office of the Secretary General, the school Directors or whoever shares the document with the APEEE, will result in the APEEE not receiving such information in the future. This will prevent the APEEE participating in discussions on those topics and so restricting its ability to do its job of representing the interests of parents.


The APEEE Board

Note: this message has been mailed to all class representatives.

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