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Subject Access Request

Request to:
Proximus (Legal hotline)
Law used:
Loi relative à la protection de la vie privée à l'égard des traitements de données à caractère personnel
Status of this request:
Request awaits classification
Summary of Request
Dear Proximus, I wish to get access to all my personal data that you hold. Note that I am not a client of your company, but that this information would have been collected while I was "roaming" in Belgium. To help you retrieve relevant information, you will find below my phone number, and the IMEI and ICCID numbers associated to my device, as well as a copy of my passport. I remind you of the definition of personal data in Belgian law: " toute information concernant une personne physique identifiée ou identifiable, désignée ci-après "personne concernée"; est réputée identifiable une personne qui peut être identifiée, directement ou indirectement, notamment par référence à un numéro d'identification ou à un ou plusieurs éléments spécifiques, propres à son identité physique, physiologique, psychique, économique, culturelle ou sociale." This definition is thus extremely broad, and would cover any information associated to my cellphone. The data I expect to get would include processed information, such as geolocation data, but also raw data such as connections to my home phone provider, and logs of communications between your cell towers and my device. I remind you of the delay of 45 days applicable to such requests.

Messages in this request

From << Name Not Public >>
Subject Subject Access Request [#12]
Date Nov. 3, 2016, 4:56 p.m.
To Proximus (Legal hotline)
Status Awaiting response

Dear Proximus, I wish to get access to all my personal data that you hold. Note that I am not a client of your company, but that this information would have been collected while I was "roaming" in Belgium. To help you retrieve relevant information, you will find below my phone number, and the IMEI and ICCID numbers associated to my device, as well as a copy of my passport. I remind you of the definition of personal data in Belgian law: " toute information concernant une personne physique identifiée ou identifiable, désignée ci-après "personne concernée"; est réputée identifiable une personne qui peut être identifiée, directement ou indirectement, notamment par référence à un numéro d'identification ou à un ou plusieurs éléments spécifiques, propres à son identité physique, physiologique, psychique, économique, culturelle ou sociale." This definition is thus extremely broad, and would cover any information associated to my cellphone. The data I expect to get would include processed information, such as geolocation data, but also raw data such as connections to my home phone provider, and logs of communications between your cell towers and my device. I remind you of the delay of 45 days applicable to such requests.
[... Show complete request text] Kind Regards, << Name Not Public >>
  1. 2 years agoNov. 3, 2016, 4:56 p.m.: << Name Not Public >> sent a message to Proximus (Legal hotline).
From VERBUSTEL Veerle (GCA/RIM) – Proximus (Legal hotline)
Subject Proximus - request for information
Date Nov. 23, 2016, 12:16 p.m.
Status Awaiting response

Dear Mr. << Name removed >>, Thank you for your e-mail. In order to reply to your request for information, Proximus wants to make sure that the request originates from the genuine Mr. << Name removed >>. The e-mail address used: <<email address>> and email address> >, seems to suggest that it has been automatically generated (via a public forum), so Proximus is cautious in providing an immediate feedback. Consequently, we invite you to re-send a new request, using a private e-mail address. Furthermore, we ask you to provide us with a copy of your identity card without masking your birth date, place of birth and your passport number in order to allow us to verify your identity and the validity of your identity document. We remain at your disposal in case of any further information. Yours sincerely, Proximus ________________________________ ***** Disclaimer ***** http://www.proximus.be/maildisclaimer
  1. 1 year, 11 months agoNov. 23, 2016, 12:16 p.m.: Received an email from Proximus (Legal hotline).
From << Name Not Public >>
Subject Re: Proximus - request for information [#12]
Date Nov. 27, 2016, 8:22 p.m.
To Proximus (Legal hotline)

Dear Proximus, This request was indeed sent through an automatically generated email address. Nevertheless I do not see why this would invalidate the request, or rather I do not understand how it would help to send the same request through a so-called "private email address". Indeed, anyone could generate an email address on a multitude of widely used services pretending to be me. You would be none the wiser. On the other hand, using automatically generated email addresses to do Subject Access Requests is sure to provide a distinct advantage to me and other users of PersonalData.IO, as there are literally thousands of companies collecting our personal data. Additionally, how would it help you to have a full copy of my identification documents? You already have the expiration date of the passport, my names and location of emission. Does Proximus have the possibility to actually check my passport number against an official database? Or even my birthday? I have included my phone number in my original request. Instead of the procedure you suggest, you could contact me at that phone number, certify that I am indeed making the request, and confirm with my phone operator my identity. ... Sincerely yours << Name removed >> << Name removed >> Request Number: 12 Reply To: <<email address>> P ost Address: << Name removed >> << Name removed >> << Address removed >>
-- Legal Note: This mail was sent through a Data Protection Portal. Replies might be published automatically.
  1. 1 year, 11 months agoNov. 27, 2016, 8:22 p.m.: << Name Not Public >> sent a message to Proximus (Legal hotline).
  2. 1 year, 11 months agoNov. 27, 2016, 8:23 p.m.: << Name Not Public >> made the request 'Subject Access Request' public.
From VERBUSTEL Veerle (GCA/ARC) – Proximus (Legal hotline)
Subject Proximus - request for information
Date Dec. 8, 2016, 12:45 p.m.
Status Awaiting response

Dear Mr. << Name removed >> , As stated previously, in order to reply to your request for information, Proximus needs to make sure that the request originates from the genuine Mr. << Name removed >> . Proximus cannot take the risk to provide personal data concerning a certain person to the wrong person. According to article 32 of the Royal Decree of 13 February 2001 (executing the Belgian Privacy Act of 8 December 1992 on the protection of privacy in relation to the processing of personal data) any individual proving his identity has the right to access the information mentioned in article 10 of the Belgian Privacy Act by means of a signed and dated request submitted with door-to-door delivery, sent by postal service or sent using a means of telecommunication. Based on the aforementioned, Proximus invites you to send a signed and dated request accompanied by a copy of your identity card either by postal service to Proximus (to the attention of Olivier Moumal - DPO, Koning Albert II-laan 27, 1030 Brussels), either scanned via e-mail to <<email address>> and email address> >. The practice of requesting a copy of the identity card is endorsed by the Belgian Privacy commission (see FR: https://www.privacycommission.be/fr/f... - NL: https://www.privacycommission.be/nl/f... - ENG: not available). We remain at your disposal in case of any further question. Best regards, Proximus Privacy Office ________________________________ ***** Disclaimer ***** http://www.proximus.be/maildisclaimer
  1. 1 year, 11 months agoDec. 8, 2016, 12:46 p.m.: Received an email from Proximus (Legal hotline).
From << Name Not Public >>
Subject Re: Proximus - request for information [#12]
Date Dec. 8, 2016, 1:05 p.m.
To Proximus (Legal hotline)

Dear Proximus, I believe it is your company's duty to route this internally correctly. Having contacted the Proximus legal department, I thought this request was addressed at the right place. However, if you insist that this request be addressed at <<email address>> , please provide me with some kind of internal reference number so my case is not lost. Sincerely, Request Number: 12 Reply To: <<email address>> P ost Address: << Name removed >> << Name removed >> <<email address>>
-- Legal Note: This mail was sent through a Data Protection Portal. Replies might be published automatically.
  1. 1 year, 11 months agoDec. 8, 2016, 1:05 p.m.: << Name Not Public >> sent a message to Proximus (Legal hotline).
From VERBUSTEL Veerle (GCA/ARC) – Proximus (Legal hotline)
Subject RE: Proximus - request for information [#12] - reference 2016_SAR_VV_111
Date Dec. 9, 2016, 11:39 a.m.

Dear, We created a specific mailbox to better serve our customers. Please use the following reference in your communication: 2016_SAR_VV_111 Proximus invites you to send a signed and dated request accompanied by a copy of your identity card (non-masked) either by postal service to Proximus (to the attention of Olivier Moumal - DPO, Koning Albert II-laan 27, 1030 Brussels), either scanned via e-mail to <<email address>> We will check the validity of your identity card via www.checkdoc.be and the correspondence of your signature on both documents. We remain at your disposal in case of any further questions. Best regards, Proximus Privacy Office
-----Original Message----- From: << Name removed >> << Name removed >> <<email address>> Sent: Thursday 8 December 2016 13:05 To: VERBUSTEL Veerle (GCA/ARC) < <name and email address> > Subject: Re: Proximus - request for information [#12] Dear Proximus, I believe it is your company's duty to route this internally correctly. Having contacted the Proximus legal department, I thought this request was addressed at the right place. However, if you insist that this request be addressed at <<email address>> , please provide me with some kind of internal reference number so my case is not lost. Sincerely, Request Number: 12 Reply To: <<email address>> P ost Address: << Name removed >> << Name removed >> <<email address>> -- Legal Note: This mail was sent through a Data Protection Portal. Replies might be published automatically. ________________________________ ***** Disclaimer ***** http://www.proximus.be/maildisclaimer
  1. 1 year, 11 months agoDec. 9, 2016, 11:39 a.m.: Received an email from Proximus (Legal hotline).