Timor-Leste National Authority for Integrity in Sport (TL-NAIS) Privacy Policy
This policy is concerned with the use of personal data related to anti-doping, including past, present and future information. The information shall be collected from the athletes and support personnel (“You”) as defined in TL-NOC anti-doping rules. The Timor-Leste National Authority for Integrity in Sport (“TL-NAIS”, “us”, “we” or “our”) shall only use the information for the purpose of anti-doping. TL-NAIS considers the protection of your personal data as our duty, and the process shall be in accordance with the International Standard for the Protection of Privacy and Personal Information (ISPPPI) set out by The World Anti-Doping Agency (WADA) and, when applicable, The Personal Data Protection Act B.E.2562 (2019).
The Scope of this Policy
This policy covers personal information past, present and future which has been received from you or about you for the purpose of doping control. It also covers the processing of your information, including storing, analysing, updating, accessing, transferring and deleting of said data.
This policy shall not be concerned with any scope outside doping control processes.
TL-NAIS shall update this policy when needed. The update shall be made known to you and TL-NAIS’s staff in advance. TL-NAIS’s staff shall strictly adhere to this policy and shall make sure any third party involved shall do the same. TL-NAIS’s staff shall be held accountable by law for the breach of this policy.
What Data Do We Collect?
- Identifiers such as a real name, alias, postal address, hometown, unique personal identifier, online identifier, Internet Protocol address, email address, account name, national card identity number, driver’s license number, passport number, or other similar identifiers;
- Data from device settings such as information you allow TL-NAIS to receive through device settings you turn on, such as access to your GPS location, camera or photos;
- Information such as signature, physical characteristics or description, telephone number, insurance policy number, education, employment, information, medical information, or health insurance information, employment history, bank account number, credit card number, debit card number, or other financial;
- Age and date of birth;
- Physical information, such as height, weight, body measurements and gender;
- Images, photos and videos;
- Internet or other electronic network activity information, including without limitation, browsing history, search history, and information regarding a consumer’s interaction with an Internet web site, application, or advertisement;
- Geolocation data;
- Information about any sports you may play or with which you are associated;
- Professional or employment-related information;
- Inferences drawn from any of the information identified above to create a profile about a person reflecting the person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
“Personal Information” does not include publicly available information. “Publicly available” means information that is lawfully made available from state, or local government records, or any conditions associated with such information. In addition, to the extent that any Personal Information is “de-identified,” it will be treated as non-Personal Information, and we may use it without obligation to you, except as prohibited by applicable law.
How Will Your Data Be Used?
Your data shall be used by TL-NAIS for the following purposes:
- To formulate our Registered Testing Pool and Test Distribution Plan including whereabouts information.
- To investigate any potential Anti-Doping Rule Violation.
- To tailor and implement our education plan.
- To carry our anti-doping related research.
- To communicate with you on anti-doping matters and processes.
- To promote international cooperation in the fight against doping in sport.
- To be used in the process of applying for a TUE.
- To be used in the process of Athlete Biological Passport.
- To be used in the process of compliance and enforcement.
- To be used in the process of Result Management.
Your data shall not be used for any commercial purposes. TL-NAIS shall be assessing the processing of your data every 3 months to mitigate any risk to your data.
Your data may be shared with other anti-doping organisations through Anti-Doping
Administration and Management system (ADAMS) in accordance with the International Standard for the Protection of Privacy and Personal Information (ISPPPI). See ANNEX B for details.
How Is Your Data Protected?
In accordance with Standard Operation Procedure SOP-SEKRE-01 about Documented Information Procedure, TL-NAIS has setup a Document Control Centre (DCC) where the movement of each document containing your personal data shall be tracked both within TL-NAIS and in the case where third party is involved. TL-NAIS has also set up a secure email and cloud server to store your information electronically. Access shall only be granted to people or people within TL-NAIS’s departments when required within each anti-doping process. Physical copies of your document and information shall be stored in locked cabinets with access available only to the DCC.
Your Rights
Under this policy, and in accordance with the Personal Data Protection Act B.E.2562 (2019), you have the rights to:
- Request to access your own personal data.
- Request to alter or update your personal data.
- Request the deletion of your personal data (subject to World Anti-Doping Code, International Standards, TL-NAIS’s anti-doping rules and applicable law).
- Request to terminate your consent.
- Request the transfer of your personal information to other anti-doping organisations.
- Lodge an official complaint with TL-NAIS on the process of Personal Data Protection.
Retention Time
The duration of the retention of your personal information is laid out in Annex A of this policy. The retention time is in accordance with the International Standard of the Protection of Privacy and Personal Information (ISPPPI).
Our Contact
Program Manager on Anti-Doping
(+670) 73013239
Timor-Leste National Authority for Integrity in Sport (TL-NAIS)
Rua de Marginal, Lecidere, Dili, Timor-Leste
ANNEX A: RETENTION TIMES
ADRV: Anti-doping rule violation
AAF: Adverse analytical finding
ATF: Atypical finding
APF: Adverse passport finding
ATPF: Atypical passport finding
- Referenced data will be deleted no later than the end of the calendar quarter following the expiry of the stated retention period.
- Retention times are limited to two categories: Twelve (12) months and ten (10) years. The period of ten (10) years represents the time period during which an action may be commenced for an anti-doping violation under the Code. The period for twelve (12) months represents the time period relevant to count three (3) whereabouts failures giving rise to an anti-doping rule violation, and is also applied to certain incomplete documentation and TUE-related information.
- Retention times can be extended in case of pending or reasonably anticipated anti-doping rule violations, investigations, or other legal proceedings.
| Module | Data | Retention Period | Remarks | Criteria |
|---|---|---|---|---|
| 1- Athlete | Athlete data relevant for practical purposes and for notification purposes in the event of an ADRV. These data are not particularly sensitive. | |||
| Athlete (general) | Name, Date of birth, Sport Discipline and Gender | 10 years as of time when Athlete is excluded from ADO’s Testing program or as of time other data categories have been deleted (see, e.g. Section 6 – ADRV), whichever is later | Necessary to notify of ADRV and to keep a record of Athletes included in an ADO’s Testing program. | Necessity |
| Contact information (phone number (S), email address, mailing address) | 10 years as of time when Athlete is excluded from ADO’s Testing program | Same as above. | ||
| 2 – Whereabouts* *(except for city, country, and In – Competition whereabouts information, which are needed for the Athlete Biological Passport- see section 7) | ||||
| Whereabouts | Whereabouts (other than city, country and in-Competition whereabouts) | 12 months as of end of the whereabout s quarter for which the data was submitted | Relevant to count 3 whereabouts failures in 12 months’ time. | Necessity |
| Whereabouts failures (filing failures and missed tests) | 10 years as of date of whereabout s failure | Relevant to count 3 whereabouts failures in 12 months’ time and to other possible ADRVs. If ADRV, will also be kept as part of results management file (see section 6). | Necessity | |
| 3 – TUEs | Destroying medical information makes it impossible for WADA/ADOS to review TUEs retrospectively after TUE has lost its validity. TUE information is largely medical and therefore sensitive. | |||
| TUE | TUE certificates and rejected TUE decision forms | 10 years as of certificate date/date of rejection decision | Can be relevant in case of retesting or other investigations. | Proportionality / Necessity |
| TUE application forms and supp. med information and any other TUE info not otherwise expressly mentioned herein. | 12 months from end of validity of TUE | Loses relevance after expiration of TUE except in case of reapplication. | Proportionality / Necessity | |
| Incomplete TUEs | 12 months from date of creation | Can be relevant in case of reapplication. | Proportionality | |
| 4- Testing | ||||
Testing | Doping Control Forms (DCFs) | 10 years as of Sample collection date | DCFs, associated mission/Testing orders, and chain of custody documents are relevant for Athlete Biological Passport and in case of reTesting of Samples. If ADRV, will also be kept as part of results management file (see section 6) | Proportionality / Necessity |
| Mission/Testing Orders | Retained until all associated DCFs have been deleted | Same as above. | Proportionality / Necessity | |
| Chain of custody | 10 years as of document creation date | Same as above. | Proportionality / Necessity | |
| Incomplete Testing documentation or documentation not matched to a Sample | 12 months as of document creation date | Documentation that is incomplete or not matched to a Sample typically results from a data entry error and is discarded after a short delay for data integrity purposes. | Proportionality | |
| 5 – Test results/Result s Management | Analytical test results (incl. AAF/ATF), laboratory reports, and other associated documentation | As of Sample collection date / date of creation of relevant documents: 10 years* | Necessary because of multiple violations and retrospective analysis. If ADRV will also be kept as part of the results management file (see section 6). *Subject to the criteria and requirements of the Code/Internationa l Standards, analytical data resulting from Sample analysis and other Doping Control information may, in certain circumstances, be kept beyond the applicable retention period for research and other purposes permitted by Article 6.3 of the Code. Samples and data must be processed to ensure they cannot be traced back to an athlete before being used for such secondary purposes. 10 years is the maximum retention time for identifiable data and Samples. See the International Standard for Laboratories for details. | Necessity Proportionality / Necessity |
| 6 – Proceedings and Decisions (ADRV) | As of date of final decision: | Managed by disciplinary body / sports federation / ADO. | ||
| Decisions and Proceedings | Sanctions and Decisions under the Code | Longer of 10 years or duration of sanction* | Necessary because of multiple violations and possible duration of sanctions. * Decisions (e.g. CAS decisions) can be important legal precedents and part of the public record; in such cases, ADOs may decide to retain a decision beyond the applicable retention period. | Necessity Proportionality / Necessity |
| Relevant documentation/file s (incl. AAF or whereabouts failure record, case files, laboratory and ABP documentation packages, etc.) | Longer of 10 years or duration of sanction | Necessary because of multiple violations and possible duration of sanctions. | Necessity | |
| 7 – Athlete Biological Passport | ||||
| Results | Biological variables, ATPF, APF, APMU reports, expert reviews and other supporting documentation. | 10 years as of date of match between results and Doping Control Form | Necessary because of multiple violations and to analyze or review biological variables, APMU reports and expert reviews over time. | Necessity |
| Whereabouts | Whereabouts (only city, country and In-Competition whereabouts) | 10 years as of end of the whereabouts quarter for which the data was submitted | Needed to support atypical/abnormal results, or to refute Athletes’ claims. | Proportionality / Necessity |
