Privacy policy: Microsoft Teams within Proximus

With this privacy policy for Microsoft Teams, Proximus wants to:

inform you about the personal data which we collect and process about you when you participate in a Microsoft Teams meeting set-up by a Proximus organiser; and
set out some guidelines on how Microsoft Teams and its functionalities should be used in a Proximus setting.

Please note that in this connection, there are two types of Microsoft Teams meetings: Channel Microsoft Teams meetings (hereinafter referred to as “Channel Meeting”) and non-Channel Microsoft Teams meetings (hereinafter referred to as “non-Channel Meeting”):

A Channel Meeting is a meeting directly organised through Microsoft Teams, specifically meant for teams created in Microsoft Teams. Such meeting is visible and free to join for anyone in Microsoft Teams that is indicated as a member of the team. Most of the Proximus teams created in Microsoft Teams include only persons with a Proximus perID (e., Proximus employees and contractors). However, in some cases, also externals are invited to join a Proximus team in Microsoft Teams and can join a Channel Meeting.
A non-Channel Meeting is a Microsoft Teams meeting organised through Outlook by putting a link to the Microsoft Teams meeting invite into the invitation mail. In most cases, externals will be invited for a non-Channel Meeting instead of a Channel Meeting at Proximus.

This policy applies to both internal invitees (i.e., persons with a Proximus perID, including contractors with a perID and a Proximus Microsoft Teams license) and external invitees to a Microsoft Teams meeting.

Which personal data do we collect for which purposes?

Access to Microsoft Teams meetings

When participating in Microsoft Teams meetings organised by Proximus, we will collect and process your e-mail address, O365 userID, profile picture (if you have set one; please see below), name and phone number (if you are joining via phone). This information will be visualised during the meeting in the gallery to give an overview of all invitees and will also be registered afterwards to show who attended to the meeting or not. In addition, the conversations in the meeting chat and the files that are shared during this meeting are stored in Microsoft Teams and accessible by all internal invitees to any meeting and external invitees to a Channel meeting. Chat conversations are never downloadable, and a participant is able to delete his own chats.

If transcript is turned on, a timestamp is added to indicate when something is said by whom. In any case, the personal data mentioned above will only be used for (i) the management and authentication of your access to the meeting, (ii) visualising the invitees (including the participants and non-participants) and, (iii) if available, the management of meeting recordings & records. This personal data will be stored for a maximum of 5 years after the date on which the related meeting has been held.

Recording of Microsoft Teams meetings

Only Proximus internal meeting participants can start (and stop) recording a Microsoft Teams meeting that was set-up by a Proximus organiser. Starting a recording enables by default the transcript of the meeting unless a Proximus internal meeting participant decides to stop the transcript immediately after the recording has started. Guests or external meeting participants do not have the technical possibility to start, nor stop the recording/transcript.

Every participant can choose to hide their identity in meetings with transcriptions turned on. The speaker attribution will only show what is said. See Microsoft’s How to hide your identity

Once recording/transcript is being started or stopped, every participant will be clearly informed by a banner popping-up on top of the screen indicating recording and transcript are started or stopped.:

Upon dialling in via phone, a similar message will be played to indicate that recording is being started/stopped.

Proximus meeting organisers:

are not allowed to switch Proximus participant-rights from “presenter” to “attendee”, unless in a training context;
shall, for those meetings for which it is known in advance that they will be recorded, mention this already in the meeting invite. If you do not agree to the recording/transcript and the sharing of this recording/transcript with the meeting invitees, you will not be able to participate as your participation (as an active action) will be considered as your consent. The recording and transcript will however then afterwards be accessible to you as described below.
shall in the beginning of each meeting clearly indicate (i) that the meeting will be recorded and transcribed and (ii) that if any of the participants do not agree to this recording, they are allowed to drop off. Upon starting a recording/transcript, there will also be a banner popping-up indicating to let everyone know that they are being recorded with a link to the Proximus Privacy policy”
shall allow participants to drop off during the meeting in case the recording/transcript does not take place from the beginning of the meeting;
shall -only on explicit request- provide the external invitees to a Channel meeting a shared link to the recording.
shall if the use of the camera could be useful during the meeting clearly indicate that this camera use is not mandatory.
Must distribute the transcript to all meeting participants, including Guests or external participants and those who joined by phone. Every participant has the right to review the transcript

The recordings/transcripts will be stored for a maximum of 5 years after the date on which the meeting has been held and will/ can only be used for:

archiving purposes (e.g., for personal reference of meeting invitees);
knowledge sharing purposes (e.g., to share the meeting recording with invitees who could not attend the meeting);
training purposes within Proximus (e.g., to record online trainings and make them available to the wider Proximus organisation through the Proximus intranet and/or other O365 apps).

Recordings/transcripts cannot be used as evidence for any other commercial or HR purposes. This is not allowed within Proximus.

Meeting recordings/transcripts are accessible afterwards as follows:

If a non-Channel meeting only pertains to internal invitees, all internal invitees will have direct access to the recording via Microsoft OneDrive or SharePoint. The recording will however not be downloadable and cannot be shared with any other persons inside or outside Proximus. The transcript can be accessed through the meeting chat and can be downloaded.
If a non-Channel meeting includes both Proximus and external invitees, all internal invitees will automatically get a personally shared link to the recording. External invitees will only receive this link on request. This request needs to be filed at the Proximus meeting organizer who will need to add the concerned external user to the shared list. The recording will however not be downloadable and can consequently not be shared with any other persons inside or outside Proximus. The transcript can be accessed through the meeting chat and can be downloaded by Proximus internal employees.

If a Channel meeting includes only internal invitees or both internal and external invitees, all invitees will automatically get a personally shared link to the recording. Other Channel Members will have access to the recording too. The recording will however not be downloadable and cannot be shared with any other persons inside or outside Proximus. The transcript can be accessed through the meeting chat and can be downloaded by Proximus internal employees. In some specific cases, it can however be needed or useful to grant a broader access to the recording within Proximus and to share it with other Proximus employees or contractors who were not invited to the meeting. In this case, only the meeting organiser or the recorder (i.e. the participant having started the recording) can grant this broader access to the recording within Proximus (e.g. at a group level or channel level, or to specific people, or companywide). This can for example be in a training context. Before granting this broader access, the meeting organiser or recorder, will however need to obtain the consent of all participants. There are two ways of obtaining this consent:

Either the Proximus meeting organiser will already clearly indicate in the meeting invite that there will be a recording and that within Proximus also other people than the invitees will get access to this recording. In this case, the meeting organiser needs to describe very clearly in the meeting invite who will get access to the recording (e.g., the whole team, department, business unit, companywide…). If -as an invitee- you do not agree to the recording and the sharing of this recording with the people indicated in the meeting invite, you will not be able to participate as your participation to the meeting will as an active action be considered as your consent. The recording will however afterwards be accessible to you, as well as to the other people indicated in the meeting invite. Any recording to which a broader access is granted than only the invitees will not be downloadable, also not for the invitees. For all persons having access to the recording, it is not allowed to share the recording with any other person inside or outside Proximus.
Or the consent can also be obtained after the recorded meeting through a dedicated (Microsoft) consent form. If one of the participants does not agree to the sharing of the envisaged recording with other Proximus employees or contractors who were not invited to the meeting, the recording cannot be granted a broader access.

For granting access to a broader audience to the transcript see section below “Transcripts only without recording of Microsoft Teams meetings”.

Live Captions

Live captions is a speech-to-text functionality. I’s: a visual aid e.g., for deaf of hard-of-hearing people or when participants are in a very noisy environment.

Every participant can start/stop Live Captions. When a participant starts Live Captions, it will be visible for every participant.

The language selected for Live Captions must be the spoken language. If a participant changes the language setting, it affects everybody in the meeting.

Live Captions will include the speaker attribution (who is speaking), meaning your profile photo (when set) and name.

Every participant can choose to hide their identity in meetings with Live Captions turned on. The speaker attribution will only show what is said. See Microsoft’s How to hide your identity.

Live Captions are permanently deleted when the meeting is over.

Transcripts only without recording of Microsoft Teams meetings

Transcripts are the literal rendering of what is being said during the Microsoft Teams meeting.

Once a transcript is being started or stopped, every participant will be clearly informed by a banner popping-up on top of the screen indicating that transcript is started or stopped.

Upon dialling in via phone, a similar message will be played to indicate that a transcript is being started/stopped.

Proximus meeting organisers:

shall, for those meetings for which it is known in advance that they will transcript, mention this already in the meeting invite. If you do not agree to the transcript and the sharing of this transcript with the meeting invitees, you will not be able to participate as your participation (as an active action) will be considered as your consent. The transcript will however then afterwards be accessible to you as described below.
shall in the beginning of each meeting clearly indicate (i) that the meeting will be transcribed and (ii) that if any of the participants do not agree to this transcription they are allowed to drop off. Upon starting a transcript, there will also be a banner popping-up indicating to let everyone know that they are being transcribed with a link to the Proximus Privacy policy
shall allow participants to drop off during the meeting in case the transcription does not take place from the beginning of the meeting;
Must distribute the transcript to all meeting participants, including Guests or external participants and those who joined by phone. Every participant has the right to review the transcript.

The transcripts will be stored for a maximum of 5 years after the date on which the meeting has been held and will/ can only be used for:

Transcripts cannot be used as evidence for any other commercial or HR purposes. This is not allowed within Proximus.

Meeting transcripts are accessible afterwards as follows:

The transcript can be accessed through the meeting chat (Non-Channel and Channel meetings) and can be downloaded by Proximus internal employees.
In some specific cases, it can however be needed or useful to grant a broader access to the transcript within Proximus and to share it with other Proximus employees or contractors who were not invited to the meeting. In this case, only the meeting organiser or the participant having started the transcription is allowed to share the transcript after being reviewed by all participants within Proximus (e.g., at a group level or channel level, or to specific people, or companywide). Before granting this broader access, the meeting organiser or the participant having started the transcription, will however need to obtain the consent of all participants. There are two ways of obtaining this consent:
- Either the Proximus meeting organiser will already clearly indicate in the meeting invite that there will be a transcription and that within Proximus also other people than the invitees will get access to this transcription. In this case, the meeting organiser needs to describe very clearly in the meeting invite who will get access to the transcription (e.g., the whole team, department, business unit, companywide…). If -as an invitee- you do not agree to the transcription and the sharing of this transcription with the people indicated in the meeting invite, you will not be able to participate as your participation to the meeting will as an active action be considered as your consent. The transcription will however afterwards be accessible to you, as well as to the other people indicated in the meeting invite. Any transcription to which a broader access is granted than only the invitees must be made non-downloadable. For all persons having access to the transcript, it is not allowed to share the recording with any other person inside or outside Proximus.
Or the consent can also be obtained after the meeting through a dedicated (Microsoft) consent form. If one of the participants does not agree to the sharing of the envisaged transcript with other Proximus employees or contractors who were not invited to the meeting, the transcript cannot be granted a broader access. For all persons having access to the transcript, it is not allowed to share the recording with any other person inside or outside Proximus

Background personalisation & content sharing

Every meeting participant has on a voluntary basis the possibility to personalise his background by uploading pictures, images, etc. This functionality is not intended to collect personal data. It is not allowed to upload any inappropriate images, nor any images containing pictures of other people.

In addition, meeting participants are not allowed to share during a meeting any content that contains special category data (such as health data, data on religious preferences, etc.).

Finally, Microsoft Teams offers the feature to use your camera during meetings. This can only be used on a voluntary basis. The Proximus meeting organiser may kindly request to turn on your camera, but always needs to mention that this is not mandatory. Consequently, you may refuse to turn on your camera (also in a training setting).

Where do we store your personal data?

Your personal data will be stored within Proximus’ O365 tenant, stored in Microsoft’s cloud platform. Proximus, a PLC under Belgian Public Law (27 bd du Roi Albert II, 1030 Brussels, Belgium) will act as the data controller for this data. Microsoft will act as the data processor, only processing your personal data to provide Proximus with the Microsoft Teams meeting functionalities, except for Microsoft legitimate business operations. For the latter, Microsoft will act as a data controller. See Microsoft’s privacy policy for more information. In the cases where, such as with Microsoft, a vendor is established in a country which does not offer an adequate level of protection under the applicable EU data protection legislation, Proximus will ensure that the appropriate safeguards are implemented such as the use of the EU Standard Contractual Clauses as adopted by the European Commission. For more information on this, please consult the Data Protection Officer (hereinafter referred to as “DPO”) at the DPO Office.

What are my privacy rights and how can I exercise them?

With regard to your own personal data, you have the right to request accessing, correcting, restricting and even deleting this data (where appropriate and in accordance with the Proximus group's Human Resources Privacy Protection Policy for internal invitees).

In addition, you can withdraw your consent at any time and without motivation for the recordings/transcripts which you consented to and/ or the sharing of these recordings/transcripts.

You may exercise the above privacy rights by sending your request to the DPO Office at: privacy@proximus.com. If you have any other questions or complaints regarding the processing of your personal data, you can also contact the DPO Office at the same address or submit a complaint to the competent Data Protection Authority. For more information: see www.dataprotectionauthority.be/contact-us.