Personal data
Is personal data processed by the State?
Yes.
For the implementation of the “LU-Alert” system, personal data is processed. Otherwise, it would not be possible to send you personalized warnings depending on the warning channel you use and according to your personal preferences.
No personal data is collected, recorded, stored, kept, used or consulted by the public authorities that are at the origin of the message sent via the “LU-Alert” system.
However, in order to ensure the technical functionalities of the “LU-Alert” mobile application, the State can access the unique technical identifier of your mobile device (generated automatically when downloading the mobile application and pseudonymized) and its IP address.
Does the State have access to the location data of the mobile devices?
No.
The sending of geolocated warning and information messages via the “LU-Alert” mobile application is based on the geolocation of your mobile device when activated it in the settings of the mobile device. The State does not have access to the location data that is stored on the mobile device.
Warning and information messages sent via location-based SMS (LB-SMS) is carried out by using the mobile network operators’ networks (e.g. 2G, 4G) via their mobile phone relay antennas. All mobile devices located within that transmission zone are targeted.
Sending warning and information messages via Cell Broadcast (CB) works in the same way as location-based SMS, except that the transmission is carried out over a dedicated telecommunication network.
Is personal data processed by the mobile network operators?
Yes.
Mobile network operators process personal data when transmitting warning and information messages via their equipment. They process traffic data, so all data processed for the purpose of routing a communication via an electronic communications network or for billing purposes, and location data other than traffic data.
Do mobile network operators have access to the location data of the mobile devices?
Yes, when sending warning and information messages via location-based SMS. The mobile network operators are subject to compliance with the General Data Protection Regulation (GDPR).
No, when sending warning and information messages via Cell Broadcast (CB).
No, when sending warning and information messages via the “LU-Alert” mobile application, but it is noted, that in this case, the location data can be accessed by the Store of the operating system of your mobile device (Apple Store or Google Play Store).
Who is the controller of the personal data processed by the “LU-Alert” system and to whom can I lodge a complaint?
For the “LU-Alert” mobile application, the data controller is the Ministry of Home Affairs and the subcontractor is the Government IT Centre (CTIE).
For the location-based SMS (LB-SMS), the data controller for the data processed when triggering a warning and information message (geographical area targeted, content of the message, choice of warning channel) is the public authority that sends the message, the subcontractor is the CTIE. For data processed for the actual transmission of the message, the data controller is your mobile network operator.
You may lodge complaints about the protection of personal data to the data controller’s data protection officer or with a data protection supervisory authority, namely the National Commission for Data Protection (CNPD):
15, Boulevard du Jazz
L-4370 Belvaux
Téléphone : (+352) 26 10 60-1
If you have not found the answer to your question among the questions above, please consult the other sections of “All about LU-Alert”. If you do not find the answer to your question there either, you can contact us directly using the contact form by clicking on the link below.