The Platform for International Cooperation on Undocumented Migrants (PICUM) (“we”) have created this privacy statement in order to demonstrate our commitment to privacy. Your right to privacy and data security is a primary concern. This privacy statement sets out the basis on which any information we collect from you, or that is provided to us, will be processed by us.

Please find below further information regarding the data you provide us and your rights in relation to the provision of such data.


  • Information Gathering And Usage
  • Your Rights
  • Security
  • Opting Out
  • Contact Details
  • Changes In This Privacy Statement


Your personal data

We intend to give you as much control as reasonably possible over your personal data (information that can be used to identify you, such as your name, email address, telephone numbers, postal address etc.). There are times when we may need to collect and process personal data from you in order to service your needs. Set out below is a list of the types of personal data we might collect from you and the purposes for which we would use it.

Types of Information
Newsletter subscriber information: first name, last name, work email or other email if provided; if provided also the following details: phone number, address, preferred language, topics of interest

Information of subscribers of other news (statements etc.)first name, last name, work email or other email if provided; if provided also the following details: phone number, address, preferred language, gender, date of birth, topics of interest

Member related information: name of organisation, name of contact, work email or other email if provided; if provided also the following details: phone number, address, preferred language, topics of interest

Information of contacts who are not subscribers of PICUM’s newsletter, other news or PICUM members: first name, last name, work email or other email if provided; if provided also the following details: phone number, address, preferred language, topics of interest

Information required to process job applications, including information contained on a CV, in an application letter and your contact information

Online identifiers and tracking information, including website preferences stored in cookies and your ISP address
Stored in PICUM’s database for dissemination of the newsletter.

Stored in PICUM’s database for dissemination of news such statements, press releases and other news according to stated areas of interest.

Stored in PICUM’s database to receive information for members such as events including the Annual General Assembly, thematic group sessions and strategy meetings; to access and use PICUM’s member only space and to receive other information relevant for membership at PICUM.

To share resources and information relevant to stated topics of interest of the contacts.

To process job applications.

To improve and tailor your website experience

We will only collect personal information from you when we need this information and we will not process your personal information other than for the purposes for which you shared it with us. You will always have the option to unsubscribe from receiving information or to request to be deleted from our database which we will do accordingly.

We do not perform any profiling activities, including automated-decision making, where your personal data is processed by automated means.

Your consent

Before collecting any personal information from you, we will generally ask you for your consent.  We may request this consent in varying forms, such as, by asking you to tick a box on a form, sign up to receive news through our website, or by asking you to provide a written or oral statement.

You may withdraw your consent at any time, by unsubscribing from the information you receive or by using the contact details below.  Please note, however, that withdrawing your consent will not affect the lawfulness of  our use of your information based on the consent you grave prior to withdrawal.

Where we store your personal data

Your personal data is stored  by PICUM and can only be accessed by selected PICUM staff for the purpose of sharing relevant information with contacts.

Receiving newsletters

We offer various free electronic newsletters. Users can sign up by clicking on the “GET NEWS” button on the homepage. We do not spam, sell or rent email addresses, and there is a link to unsubscribe from the newsletter in every email you’ll receive as well as a link to be completely removed from our database. Alternately you may remove your address from our mailing lists by sending an email to communications@picum.org.

Processing your data for our legitimate interests

In some cases we will process your personal data for our legitimate interests, rather than seeking your consent. This is largely so that we can efficiently provide you with information without having to seek individual consent for every communication with you (or where in some cases it might not be possible for us to seek your consent). We will, however, always provide you with information on our data processing activities on request. For example, we may process your personal data:

  1. If you are a member, in order to provide you with information relevant to your membership;
  2. Where you have subscribed to one of our newsletters and we want to inform you about another newsletter or new resources relating to a similar or related topic ; or
  3. Where a new form of processing would be more efficient.

Before undertaking such processing, we will consider your rights and freedoms and will only commence such processing where we do not think your rights will be infringed.

Information sharing

We may share the personal data that you provide us with partners, to the extent necessary for the purpose of providing required information. You will generally be notified if your data is shared. This may include data of event registrations needed to access the European Parliament or other locations where events organised by PICUM are held.

We may also share personal data with or with third parties who provide services to PICUM, such as IT service providers, software platform providers and external advisors.  In that case, we will ensure that those third parties will treat your information with the necessary care and confidentiality and we will put in place the required contractual documentation.

We will not otherwise use, share, disseminate, publish or disclose your personal data (except as may be required in response to litigation, investigations or other legally required disclosures).

Period for which we store your personal data

We will ensure that the period for which we store your personal data is limited to a strict minimum.  We will store your personal data for no longer than is necessary for the purposes of providing the information you have requested or as required for legal compliance purposes. For further information on how long we will store your personal data in any particular case, please do not hesitate to contact us using the details below.

Links to third-party websites

Our website may contain links to other websites of interest. However, once you have used these links to leave our website, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such websites and such websites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.

Message boards/forums

This website may make forums and message boards available to you. Please remember that any information that is disclosed in these areas becomes public information. You should exercise caution when deciding to disclose your personal data.


Access.  You may contact us at any time in order to request access to the personal information we hold about you. We will confirm whether we are processing your personal data, provide details of the categories of personal data concerned and the reasons for our processing. We can also provide you with a copy of your personal information on request.

Rectification.  If the information we hold appears to be inaccurate we will not use it, and not allow others to use it, until it is verified. You can ask us to correct or complete your personal data by contacting us at any time.  To the extent possible, we will inform anyone who has received your personal data of any corrections we make to it.

Restriction.  In certain circumstances, it may be possible to require us to limit the way in which we process your personal information (i.e., require us to continue to store your personal data, but not otherwise process it without your consent). Such circumstances include:

  1. where you think the data we hold about you is inaccurate, processing can be restricted while it is being rectified;
  2. where you object to our processing, (which is being carried out on the grounds that it is necessary for our legitimate interests) processing can be restricted while we determine whether such grounds override your interests
  3. where processing is unlawful but you oppose the erasure and request restriction of your data instead; and
  4. where we no longer need the personal data but you require the data in order to establish, exercise or defend a legal claim, our processing can be restricted.

Removal of your data.  You may ask to have the information on your account deleted or removed.  We will try to do so promptly, and, to the extent possible, we will inform anyone who has received your personal information of your request. However, we must keep track of certain transaction information, such as past event registrations and similar information, for legal compliance purposes of our funders and accountants, so we may not be able to fully delete your information in certain circumstances.

Receiving/transferring your personal data. You may also ask us to send you the personal data we hold on you in an electronic, structured and user-friendly format, or you may ask us to send this data to another person.

Object.  Where we are processing your personal information without your consent to pursue legitimate interests, you may object to us processing your personal data. In particular, where we are using your personal data to contact you for  purposes of sharing information and resources, you may object to such processing at any time.

Complaints. If you are located in the EEA and you believe that our processing of your personal data is in breach of data protection law, you have the right to lodge a complaint with the relevant data protection supervisory authority in the country where you are based or any place in the EEA where you believe the infringement has occurred. You may also contact us at any time if you wish to complain about our processing of your personal data.

For any of the requests listed above, please use the contact details below. We will make reasonable efforts to respond promptly and at the latest within one month. Our response to such requests may be limited to information under our direct control.


Security measures

We limit access to personal data that we collect about you to our employees, who we reasonably believe need to have access to your information to provide you with the information you request from us. We have security measures in place to help protect against the loss, misuse and alteration of the information under our control. While we cannot guarantee that loss, misuse or alteration to data will not occur, we ensure that our systems adhere to market security standard so as to help safeguard against such occurrences.  In case you have any questions about these measures, please use the contact details provided below.

However, no method of transmission over the Internet, or method of electronic storage is 100% secure. We will use commercially acceptable means to protect your personal data, but we cannot guarantee its absolute security. If you have any questions about our security, you can email us through the contact below.

Children’s privacy protection

PICUM does not target and its websites are not intended for children under the age of 16. PICUM will not knowingly collect personal data from children, and will delete such data upon discovery. Where PICUM requires personal data pertaining to children for the purpose of providing information, the consent of an adult with parental responsibility for that child will be required.


If you do not wish to receive certain communications from us you may opt out by: (1) following the opt out instructions that we include in each of our communications with you or  (2) informing us at communications@picum.org that you no longer wish to receive such communications. We will comply with such requests unless such communications from us are required by law or do not require your consent under applicable laws. Your opting out may restrict our ability to provide you with the full extent of our services.


We use “Google reCAPTCHA” (hereinafter “reCAPTCHA”) on our websites. This service is provided by Google Inc., 1600 Amphitheater Parkway, Mountain View, CA 94043, USA (“Google”).

reCAPTCHA is used to check whether the data entered on our website (such as on a contact form) has been entered by a human or by an automated program. To do this, reCAPTCHA analyzes the behavior of the website visitor based on various characteristics. This analysis starts automatically as soon as the website visitor enters the website. For the analysis, reCAPTCHA evaluates various information (e.g. IP address, how long the visitor has been on the website, or mouse movements made by the user). The data collected during the analysis will be forwarded to Google.

The reCAPTCHA analyses take place completely in the background. Website visitors are not advised that such an analysis is taking place.

Data processing is based on Art. 6 (1) (f) DSGVO. The website operator has a legitimate interest in protecting its site from abusive automated crawling and spam.

For more information about Google reCAPTCHA and Google’s privacy policy, please visit the following links: https://www.google.com/intl/eng/policies/privacy/ and https://www.google.com/recaptcha/intro/android.html.


If you would like to get in touch with us with regards to your personal data, please contact us at:
Platform for International Cooperation on Undocumented Migrants (PICUM)
Paul Geeraerts
Finance Director
Rue du Congrès 37 – 41
1000 Brussels
+32 2/210.17.83


This statement was last updated on 23 August 2018. If we decide to change our privacy policy, we will post those changes to this privacy statement on our website and other places we deem appropriate so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. We reserve the right to modify this privacy statement at any time, so please review it frequently. If we make material changes to this policy, we will notify you by email, or by means of a notice on our website home page.