14. ANTI-DOPING PRIVACY NOTICE
The FIE is a signatory to the World Anti-Doping Code (the Code) and is responsible for implementing an anti-doping program in fencing This Privacy Notice describes how we will collect, use and share personal information about you to run our anti-doping program and create a clean sport environment for all athletes.
We may update this Anti-Doping Privacy Notice from time to time in order to reflect changes we make to our privacy practices. If we make material changes to this Anti-Doping Privacy Notice, we will give you notice of these changes by posting the revised policy on our website and, where necessary, by other means.
The types of personal information we collect depend on your level as an athlete or your role in sport. It will also depend on how the anti-doping rules apply to you.
For example, if you need a therapeutic use exemption, you will need to provide certain medical information. If you are charged with an anti-doping rule violation (ADRV), you may need to provide evidence in your defense. If you are not an athlete, we still may need to collect personal information about you, like education data and identifiers, but we will not ask you for whereabouts or need you to participate in anti-doping testing.
Information that identifies or is identifiable to you, like your name, contact information, date of birth, gender, nationality, and the sports you participate in and your sports results and performance-related data.
Education data we need to make sure you are receiving anti-doping education, like the courses you complete, the dates you took them, and your assessment scores.
Whereabouts information that indicates where you can be found for anti-doping testing (for example, addresses for regular activities like training, work or school and for the location(s) where you will be available for testing during a daily one-hour time slot). We will inform you if you need to provide us with this information.
Testing data that is created when we collect samples from you for an anti-doping test. (for example, doping control forms, type of test, sample code numbers, responses and information provided by you during a sample collection session) and the laboratory results from the analysis of your samples.
Athlete Biological Passport (ABP) data, for example, biological passport ID, blood and steroid biological marker values and ratios, and expert recommendations and assessments. The ABP is another tool to identify doping based on the analysis of laboratory results obtained from anti-doping samples.
Medical information, if you need to apply for a Therapeutic Use Exemption because you have a medical condition and need to use a substance or a method that is normally not allowed to be used.
Results management information, if we believe you have broken anti-doping rules. This includes information about the ADRV you are charged with, evidence you provide in defense of a charge, and the decision on whether or not you will receive a sanction.
Investigations information if we suspect you may have broken anti-doping rules. This can include information or evidence obtained from open source searches, from witnesses and other confidential sources, or through cooperation with law enforcement agencies.
Our role as an anti-doping organization (ADO) is to detect, deter and prevent doping in sport, in accordance with the Code, the International Standards (IS), and our FIE Anti-Doping Rules. This involves using personal information to carry out the following anti-doping activities:
Main Personal Information Types Used for Each Activity
Providing anti-doping education to you.
Planning and conducting anti-doping tests, and locating you for these tests using the whereabouts information you submit.
Analyzing the results from your biological samples.
Analyzing and following up on the recommendations and results of your passport (Athlete Biological Passport or ABP).
Enforcing the FIE Anti-Doping Rules by identifying ADRVs, issuing charges, and managing related proceedings.
Processing requests to grant or recognize any therapeutic use exemptions (TUE) you apply for.
Gathering intelligence and conducting investigations to better target testing activities and identify ADRVs, including cooperating with law enforcement.
Communicating with you for the purposes described above.
Coordinating and collaborating with other ADOs, for example, by sharing intelligence to better target our testing activities or by sharing information about our education program to avoid duplication.
Reporting on our anti-doping activities to WADA to demonstrate our compliance with the Code and International Standards.
Other activities authorized by the Code for purposes relating to the protection of clean sport and the enforcement of the FIE Anti-Doping Rules
We also maintain records to improve, monitor and report on our anti-doping activities. This can include creating statistics by aggregating personal information. For example, we create statistics about anti-doping tests we conduct and ADRVs for which we are the results management authority.
We may need to share your personal information with the following individuals and organizations to run our anti-doping program and respect the Code:
- Individuals you authorize to receive or share your personal information, like an agent, coach, doctor, or a parent or guardian.
- Code Signatories that have testing authority, sample collection authority, or results management authority over you, like a National Anti-Doping Organization, International Federation, or Major Event Organizers.
- WADA (the World Anti-Doping Agency), that ensures all Code Signatories respect the rules of the Code. WADA also operates and manages the Anti-Doping Administration System (ADAMS), a platform hosted in Canada to which we will upload your personal information. Using ADAMS facilitates the collaboration and sharing of information needed to run our anti-doping program
- Laboratories and Athlete Passport Management Units that analyze anti-doping samples and the Athlete Biological Passport. They are subject to the International Standard for Laboratories, and only have access to coded data (based on sample codes or passport IDs).
- The International Testing Agency (ITA), that is an international organisation constituted as a not-for-profit foundation established in Switzerland, providing independent expert anti-doping serivces to ADOs. The [IF] has contractually delegated the management and implementation of parts of the FIE anti-doping programme to the ITA. As part such delegation, the ITA is duly authorized to collect and process personal data in the context of the implementation and enforcement of the FIE anti-doping programme in accordance with the FIE Anti-Doping Rules.
- Other delegated third parties and service providers that we hire to help us carry out anti-doping activities and maintain
our operations. We require delegated third parties and service providers
to agree to strict contractual controls designed to protect your
- National Federations and Continental Federations, that may receive disciplinary notices or other information concerning their athletes or other affiliated persons.
- Disciplinary panels and hearing bodies (including the Court of Arbitration for Sport), for adjudicating ADRVs
and/or other disciplinary offences in accordance with the Code and/or
other applicable regulations.
- Public authorities and other relevant bodies (including law enforcement agencies) responsible for enforcing sport and anti-doping laws and for investigating offences tied to doping in sport.
In accordance with the Code, some of your personal information, such as your name, sport and other anti-doping related data may be publicly disclosed in cases where you have been charged with or convicted of an anti-doping rule violaiton. Your personal information may also be disclosed to third parties in any event where such disclosure (a) is required by law, regulation or compulsory legal process, (b) takes place with your consent, or (c) is necessary to assist law enforcement or governmental or other authorities in the detection, investigation or prosecution of a criminal offence or breach of the Code, provided that the personal information is reasonably relevant to the offence in question.
We process your personal information where necessary and proportionate to our anti-doping program. Under data protection laws, we rely on the following “legal grounds” or “bases” to process personal information for anti-doping activities:
- with your consent; for instance, when you apply for a TUE;
- to comply with anti-doping laws, sports laws, or other applicable laws or compulsory legal processes;
- to serve the substantial public interest of eliminating doping in sport;
- to perform a contract or take necessary steps prior to entering a contract; and
- to fulfill legitimate interests associated with the activities of an ADO
- to protect your vital interests or those of another person
on applicable legal provisions authorising the processing of personal
information for the purpose of fighting against doping.
You have rights with respect to your personal information under the International Standard for the Protection of Privacy and Personal Information and data protection laws, including the right to a copy of your personal information and to have it corrected, blocked or deleted in certain circumstances. You also have the right to lodge a complaint with us.
Because anti-doping is a mandatory feature of organized sport, it still may be necessary for us, the ITA, WADA, and other ADOs and organizations to continue to process your personal information to fulfill obligations under the Code, the International Standards, or national anti-doping or sport laws, despite your objection to such processing or withdrawal of consent (where applicable). This includes processing for investigations or proceedings related to possible ADRVs, as well as processing to establish, exercise or defend against legal claims involving you, WADA and/or an ADO. Objecting or withdrawing consent could also have consequences for you, such as triggering your non-compliance with the Code and IS, as well as the FIE Anti-Doping Rules; producing an ADRV (e.g., under Article 2.3 of the Code – Evasion, Refusal or Failure to Submit to Sample Collection); or preventing you from participating in sporting events.
Please Contact Us to exercise your rights or if you have questions or complaints about how we handle personal information.
We have adopted measures, including administrative, technical, physical and contractual measures, to protect personal information in our custody and control against theft, loss and unauthorized access, use, modification or disclosure.
We restrict access to personal information on a need-to-know basis to employees and authorized delegated third parties and service providers who require access to fulfill their designated functions. The ADOs we share personal information with are bound by the same standards as us when they handle your personal information. These standards are described in the International Standard for the Protection of Privacy and Personal Information. They include protecting your personal information, deleting it when no longer needed, being transparent, and allowing you to exercise rights like the right to access your personal information.
Your personal information will be kept in accordance with the criteria and retention periods set out in Annex A of the ISPPPI. Retention periods in Annex A can be extended where required by law or for the purpose of conducting an anti-doping investigation or proceeding or for other purposes authorized by the law.
If you have any questions about how we handle personal information, or have any complaints, please contact us at email@example.com or Avenue de Rhodanie 54, 1007 Lausanne,
For any query regarding the processing of personal data by the ITA, you can contact them at firstname.lastname@example.org or by courier at: International Testing Agency (ref. Data Privacy), Avenue de Rhodanie 40b, 1007 Lausanne, Switzerland.
If you are not satisfied with how we have handled any potential complaint, you may notify WADA at email@example.com or firstname.lastname@example.org. WADA will handle the notice in accordance with the International Standard for Compliance by Signatories.