This page is designed for AIIC regional bureaux and representatives. It provides as much guidance as possible on preparing GDPR-compliant disclaimers for your AIIC activities.
These disclaimers are at your disposal and should be used when you organize events, both for AIIC members only or public events, and when you collect data for subsequent use, such as sending mass emails. They may also serve as templates that you can customize, as appropriate.
These disclaimers were prepared in consultation with AIIC lawyers. However, we suggest that you ascertain the provisions of the applicable local laws. Your lawyers should advise you on the proper use of disclaimers under your local or regional laws.
1. Event registration consent for example PriMs (image and data) - EN / FR
2. Attendance list authorising taking photos or audio-visual means - EN / FR
3. Disclaimer on the use of audio-visual data taken at AIIC events - EN / FR
4. Disclaimer for videoconference meetings - EN / FR
5. Disclaimer for distribution list of "regional offices", groups, committees and sectors - EN / FR
6. Disclaimer for distribution list used by individual members - EN / FR
7. AIIC Library Database Release - EN / FR
8. Disclaimer for the use of the Survey Monkey application - EN / FR
9. Disclaimer to be displayed at event input - EN / FR
In addition to the disclaimers, we suggest that you visit our Q&A section that provides answers to some queries previously raised by your colleagues. This section will be updated by the Secretariat as new requests for clarification are received, after consultation with our lawyers, if necessary.
What about “voice data”? What happens when these people take the floor and their voice is recorded? Voice is a form of personal data, isn’t it? Are we supposed to cut off all the bits in which they are talking? Lots of editing… very expensive and very funny video as a result.
Where someone has refused to sign the disclaimer, their voice MUST NOT be recorded if they take the floor (applies to one or several persons).
What happens if people refuse to sit in a “secluded” area?
In this case, the event organizer must inform them that they might find themselves within range of the camera and that they consequently accept being included in the footage. In other words, should they refuse the measures applied by the organizer in order to comply with their request not to be recorded (sound and image), they nullify their objection to being recorded. Ideally, the organizer should announce this fact as well as the ensuing consequences at the start of the video/audio recording, to ensure that proof of the ‘warning’ is kept and can be produced if needed.
In Montreal, we knew very well that xxx and yyy had not signed the disclaimer, but the video maker had a system by which the microphone was connected to the camera and when they would take the floor the camera would move towards them. This is the reason why we ended up with them being filmed. Are we supposed to stop using technologies which improve the recording and make videos more interesting for the rest of the members?
VSee the first answer above. The organizer MUST be able to avoid filming or recording someone who has refused to sign the disclaimer, providing such person does not intentionally place themselves in view of the camera. Any voice recording should in any case be cut if it is identifiable.
What happens if one of the participants takes a picture of the audience and post it on social media and the people who have not signed the GDPR are in the picture, are we still responsible?
The answer to this question can be found at the end of the new disclaimer sent to PRIMS: «AIIC and its partners are not responsible for photos taken or videos made by other participants».