Lao National Anti-Doping Organization (LAO NADO) Privacy Policy

admin 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 LAO NADO anti-doping rules.  The Lao National Anti-Doping Organization (“Lao NADO”, “us”, “we” or “our”) shall only use the information for the purpose of anti-doping. LAO NADO 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 Law 

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.

LAO NADO shall update this policy when needed.  The update shall be made known to you and LAO NADO’s staff in advance. LAO NADO’s staff shall strictly adhere to this policy and shall make sure any third party involved shall do the same.  LAO NADO’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 LAO NADO 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 LAO NADO 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. LAO NADO 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, LAO NADO has setup a Document Control Centre (DCC) where the movement of each document containing your personal data shall be tracked both within LAO NADO and in the case where third party is involved.  LAO NADO 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 LAO NADO’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, LAO NADO’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 LAO NADO 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

Lao National  Anti-Doping Organization

Kounboulom Road, Chanthabouly district, Vientiane Capital Lao PDR

Tel: 021 255 168

 

ANNEX A:  RETENTION TIMES

ADRV: Anti-doping rule violation

AAF: Adverse analytical finding

ATF: Atypical finding

APF: Adverse passport finding

ATPF: Atypical passport finding

  1. Referenced data will be deleted no later than the end of the calendar quarter following the expiry of the stated retention period.
  2. 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.
  3. 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 whereabouts 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
whereabouts 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/files (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