VET-PASS

VET-PASS Privacy Notice

Last updated: 2026-09-29

Analytics — what we collect and why no consent is needed

This site uses Umami Analytics, a self-hosted, open-source tool running on EBVS-managed infrastructure in the EU. Umami is designed to be GDPR-compliant without requiring consent, for the following reasons:

  • No cookies. Umami does not set any cookies or use local storage.
  • No IP address retention. Your IP address is used only at the moment of the page request to derive a country estimate, then immediately discarded. It is never written to disk.
  • No persistent identifier. Umami uses a daily-rotating hash of IP + browser user-agent to de-duplicate page views within a single day only. This hash cannot identify you across days or sessions, and cannot be linked to any other data.
  • No cross-site tracking. Analytics are scoped to this domain only.
  • No profiling. No individual user profiles are built or stored.

We record, per page view: the page path, the referring URL, the country (derived from IP, which is then discarded), device type (phone / tablet / desktop), browser family, and browser locale.

Because no cookies or persistent identifiers are used, this analytics approach does not fall within the scope of the EU ePrivacy Directive's consent requirement. Under the GDPR, processing is carried out on the basis of our legitimate interest in understanding aggregate site usage. No consent banner or opt-out is required or provided.

Who we are

This website (vet-pass.eu) supports VET-PASS, a COST Action on veterinary specialisation across Europe. The Action is managed by the European Board of Veterinary Specialisation (EBVS), which acts as data controller for the information collected through this site. You can contact us at privacy@vet-pass.eu.

Participation in the Action itself is administered through e-COST, operated by the COST Association, which has its own privacy notice and is a separate controller for the data you enter there. This notice covers only the data you provide through this website.

Applications are made in e-COST, not here

Applications to join a Working Group and to apply for grants (STSMs, Training Schools, Virtual Mobility and conference grants) are made through e-COST, the COST Association's platform. There is no application form on this website and we do not collect your application details here. e-COST is a separate data controller with its own privacy notice.

What this website processes

Through this website we process only: (a) the minimal, anonymous analytics described above; (b) for signed-in committee and Working Group members, the personal data needed to run the Action — typically your name, email address and role, much of which originates from e-COST; and (c) a record of the emails we send you, such as task and meeting notifications, so we can confirm delivery.

We use this to operate the Action's working tools — meetings, tasks, deliverables and documents — to contact participants about their work, and to report on the Action's geographical spread, inclusiveness and gender balance, as COST requires. Our lawful basis is our legitimate interest in running and reporting on the Action, and, where applicable, your participation in it. Any equality-monitoring data (such as gender) is a special category under Article 9 of the GDPR; it is provided only with explicit, optional consent, used solely for aggregate monitoring, and never to make decisions about your participation.

How we use inclusiveness data

Career stage, country, and gender feed aggregated, anonymised statistics on participation across the Action (for example, the proportion of Young Researchers and Innovators or participants from Inclusiveness Target Countries). Reporting is at aggregate level and does not identify individuals.

Who can see it

Your data is accessible to the VET-PASS coordination team who process membership and inclusiveness reporting. We do not sell your data or share it with third parties for marketing. Where necessary to administer your Action membership, relevant details are held in e-COST, at which point COST's own privacy notice applies. We use a data processor to host this website; it is bound by a data-processing agreement and may not use your data for its own purposes.

Where it is stored

The data we process is stored on EBVS-managed infrastructure hosted within the EU/EEA. Where any processor is located outside the EEA, we ensure an adequate safeguard (such as an adequacy decision or standard contractual clauses) is in place.

How long we keep it

We keep members’-area data for the duration of the Action and for a reasonable period afterwards for reporting and continuity, after which it is deleted or fully anonymised. If you ask us to remove your data sooner, we will do so unless we are required to retain it.

Your rights

Under the GDPR you have the right to access your data, to correct it, to have it deleted, to restrict or object to processing, to withdraw consent at any time, and to data portability. Withdrawing consent does not affect processing carried out before you withdrew it. To exercise any of these rights, contact us at privacy@vet-pass.eu.

You also have the right to complain to a data protection authority. EBVS is established in the Netherlands, so the lead authority is the Dutch Data Protection Authority (Autoriteit Persoonsgegevens); you may also complain to the supervisory authority in your own country.

Changes to this notice

We may update this notice as the Action develops. The current version and its date are always shown at the top of this page.