Data Privacy


The European Network of Prosecutors for the Environment aisbl (“ENPE”) respects your privacy and is committed to protecting your personal data.  This privacy policy discusses how we look after your personal data and tells you about your privacy rights and how the law protects you.



This privacy policy aims to give you information on how ENPE collects and processes your personal data including any data you may provide by applying for Membership of ENPE or through ENPE’s website.


ENPE is the controller and responsible for your personal data.
We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy.  If you have any questions, including any requests to exercise your legal rights, please contact us by email:
You may complain about ENPE’s use of your personal data at any time to the Data Protection Authority (Autorité de protection des données (APD)), the Belgian supervisory authority for data protection issues (  We would, however, appreciate the chance to deal with your concerns before you approach the APD so please contact us in the first instance.
We keep our privacy policy under regular review.  This version was last updated on 25 May 2018.
It is important that the personal data we hold about you is accurate and current.  Please keep us informed if your personal data changes during your relationship with us. 
Our website may include links to third-party websites, plug-ins and applications.  Clicking on these may allow third parties to collect or share data about you. We do not control these third-party websites plug-ins and applications and are not responsible for their privacy statements.


We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
  • Identity Data including your name, job title and title;
  • Contact Data including your postal address, email address and telephone number;
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform;
  • Profile Data including your username and password; and
  • Usage Data including information about how you use our website.
We also collect, use and share Aggregated Data, such as statistical data, for any purpose.  Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity.  For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature.  However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
We do not collect any Special Categories of Personal Data about you (eg details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data).  Nor do we collect any information about criminal convictions and offences.


Where we need to collect personal data and you fail to provide that data when requested, we may not be able to provide services to you (eg access to our caselaw database or Membership of ENPE).  In this case, we may be unable to offer our service but we will notify you if this is the case at the time.


We use different methods to collect personal data including through:
  • Direct interactions. You may give us your Identity, Contact and Profile Data by filling in forms or by corresponding with us by post, phone, email or otherwise.  This includes personal data you provide when you:
    • apply for Membership or Observer status in respect of ENPE;
    • create an account on our website;
    • subscribe to our publications; or
    • give us feedback or contact us.
  • Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data.  We collect this personal data by using cookies and other similar technologies.


We will only use your personal data when the law allows us to.  Most commonly, we will use your personal data in the following circumstances, where:
  • we need to, to provide services that you have requested such as by applying for Membership of ENPE and/or for access to our caselaw database and/or to receive our newsletters;
  • it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; or
  • we need to comply with a legal obligation.
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so.  We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.  Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Type of data
Lawful basis for processing
To register you as a new contact and to provide you with information, news and updates concerning our network and activities


(a) Identity
(b) Contact
  1. Consent
  2. Necessary for our legitimate interests (to further our objective of supporting the operative work of environmental prosecutors and their implementation of environmental law)
To register you as a user of our caselaw database
(a) Profile
(b) Contact
(a) Consent
(b) Necessary for our legitimate interests (to further our objective of supporting the operative work of environmental prosecutors and their implementation of environmental law)
To register you or your Organisation as a Member or Observer of our network and, where relevant, to register you as your Organisation’s Permanent Representative to our network
(a) Identity
(b) Contact
(a) Consent
(b) Necessary for our legitimate interests (for the management and governance of our network and to further our objective of supporting the operative work of environmental prosecutors and their implementation of environmental law)
To manage our relationship with you which will include:
(a) notifying you about changes to our terms or privacy policy
(b) asking you to provide feedback
(a) Identity
(b) Contact
(c) Profile
(a) Necessary to comply with a legal obligation
(b) Necessary for our legitimate interests (to keep our records updated and to study how users use our services)
To administer and protect our network and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a) Identity
(b) Contact
(c) Technical
(a) Necessary for our legitimate interests (for running our network, provision of administration and IT services, security, to prevent fraud)
(b) Necessary to comply with a legal obligation
To deliver relevant website content to you and measure or understand the effectiveness of the content we provide
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Technical
(a) Necessary for our legitimate interests (to study how you use our services, to develop them, to grow our business and to inform our communications strategy)
To use data analytics to improve our website, services, contact relationships and experiences
(a) Technical
(b) Usage
(a) Necessary for our legitimate interests (to define types of contacts for our services, to keep our website updated and relevant, to develop our network and to inform our communications strategy)
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what information we think you may want or need from us, or what may be of interest to you (such as details of events run by ENPE or third parties, newsletters, training materials, reports and guidance).  Unless you opt out of doing so, you will receive communications from us if you have requested information from, or registered with, us.
We do not routinely share your personal data with any third party for marketing purposes.  If, exceptionally, we would like to use your personal information in this way we will get your express opt-in consent before doing so.
You can ask us to stop sending you communications by contacting us at any time.  Where you opt out of receiving these messages, this will not apply to personal data provided to us as a result of your / your Organisation’s Membership of, or Observer status with, ENPE.
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.  If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.


We may share your personal data with the parties set out below for the purposes set out in the table above.
  • internal third parties, being ENPE's Board members and secretariat; and
  • external third parties, being:
    • our partner networks (eg IMPEL, EUFJE and EnviCrimeNet) and EU institutions (eg Eurojust, Europol, the European Commission)
    • service providers who provide IT and system administration services;
    • professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services; and
    • regulators and other authorities who require reporting of processing activities.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law.  We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.


We do not transfer your personal data outside the UK or the European Economic Area (EEA).


We have put in place security measures to prevent your personal data being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.  In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.


We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.


Under certain circumstances, you have rights under data protection laws in relation to your personal data, to:
  • request access to your personal data;
  • request correction of the personal data that we hold about you;
  • request erasure of your personal data;
  • object to processing of your personal data where we are relying on a legitimate interest (or those of a third party);
  • request restriction of processing of your personal data;
  • request the transfer of your personal data to you or to a third party; and
  • withdraw consent at any time.
If you wish to exercise any of these rights, please contact us.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights).  However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
As a security measure, we may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights).  We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month.  Occasionally it could take us longer, for example if your request is particularly complex or you have made a number of requests.  In this case, we will notify you and keep you updated.