International Standard for the Protection of Privacy and Personal
Information
The World Anti-Doping Code International Standard for the Protection ofPrivacy and Personal Information is a mandatory International Standard
developed as part of the World Anti-Doping Program. It was developed inconsultation with Signatories, public authorities, and other relevant
stakeholders.
The International Standard for the Protection of Privacy and Personal
Information was first adopted in 2009 and came into effect in June 2009. It
was subsequently amended two times, the first time effective January 2015
and the second time effective June 2018. A revised version to come into force
on 1 January 2021 was approved by the WADA Executive Committee at theWorld Conference on Doping in Sport in Katowice on 7 November 2019.
Following a limited supplementary consultation period, a further revised
version was approved by the WADA Executive Committee on 15 September
2020 and is effective as of 1 January 2021.This version incorporates minor,
clarifying revisions to Annex A, which were approved by the WADA Executive
Committee on 24 November 2021, and has been effective since this date.

Published by:World Anti-Doping Agency
Stock Exchange Tower
800 Place Victoria (Suite 1700)
PO Box 120
Montreal, Quebec Canada
H4Z 1B7
www.wada-ama.org
Tel:+1 514 904 9232
Fax:
+1 514 904 8650
E-mail: code@wada-ama.org

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TABLE OF CONTENTSPART ONE: INTRODUCTION, CODE PROVISIONS, INTERNATIONAL STANDARD PROVISIONSAND DEFINITIONS ..................................................................................................................................4
1.0

Introduction and scope .................................................................................................................4

2.0

Code provisions ............................................................................................................................4

3.0

Definitions and interpretation ......................................................................................................5
3.1. Defined Terms from the 2021 Code that are used in the International Standard for theProtection of Privacy and Personal Information ...................................................................... 5
3.2. Defined Terms from the International Standard for Testing and Investigations ...................... 7
3.3. Defined Terms Specific to the International Standard for the Protection of Privacy andPersonal Information ...............................................................................................................8
3.4. Interpretation ...........................................................................................................................9PART TWO: STANDARDS FOR HANDLING PERSONAL INFORMATION ........................................ 10
4.0

Processing Personal Information in Accordance with International Standard andApplicable Law ...........................................................................................................................10

5.0

Processing Relevant and Proportionate Personal Information .............................................. 11

6.0

Processing Personal Information in Accordance with a Valid Legal Ground ....................... 12

7.0

Ensuring Appropriate Information is Furnished to Participants and Other Persons ........... 14

8.0

Disclosures of Personal Information to Other Anti-Doping Organizations andThird Parties.................................................................................................................................16

9.0

Maintaining the Security of Personal Information .................................................................... 17

10.0 Retaining Personal Information Where Relevant and Ensuring its Destruction ................... 18
11.0 Rights of Participants and Other Persons with Respect to Personal Information ................ 19
ANNEX A: RETENTION TIMES .............................................................................................................21

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PART ONE: INTRODUCTION, CODE PROVISIONS, INTERNATIONAL STANDARD
PROVISIONS AND DEFINITIONS
1.0

Introduction and Scope
The purpose of the International Standard for the Protection of Privacy and Personal Information isto ensure that Anti-Doping Organizations apply appropriate, sufficient and effective privacy
protections to the Personal Information they Process when conducting anti-doping programs, inrecognition of the fact that Personal Information gathered in the anti-doping context can impinge
upon and implicate the privacy rights of Persons involved in and associated with organized sport.
The Code, in particular, requires Athletes to furnish a significant amount of Personal Information to
Anti-Doping Organizations. As a result, it is essential that Anti-Doping Organizations appropriately
protect the Personal Information that they Process both to meet legal standards and to ensure thecontinued confidence and trust of those involved in organized sport.
The Code recognizes and affirms the importance of ensuring that the privacy rights of Persons
subject to anti-doping programs based on the Code are fully respected. In support of thiscommitment, this International Standard sets forth a minimum, common set of rules to which AntiDoping Organizations must conform when Processing Personal Information pursuant to the Code.
In some cases, Anti-Doping Organizations may be required by applicable laws to apply rules orstandards that exceed those set forth in this International Standard.
A WADA expert reference group reviewed, discussed and prepared this document, and specificallytook into account the Organization for Economic Cooperation and Development’s (OECD) 1980
Guidelines on the Protection of Privacy and Transborder Flows of Personal Data; the Council ofEurope Convention for the Protection of Individuals with regard to Automatic Processing of Personal
Data (ETS. No. 108); the APEC Privacy Framework; the Charter of Fundamental Rights of theEuropean Union, EU Regulation 2016/679 on the protection of natural persons with regard to theprocessing of personal data (General Data Protection Regulation), and other international andregional data privacy rules, standards and case law, such as the judgement of the European Courtof Human Rights of 18 January 2018 (FNASS and others vs. France).
Terms used in this International Standard that are defined terms from the Code are italicized. Terms
that are defined in this or another International Standard are underlined.

2.0

Code Provisions
The following articles in the Code are directly relevant to the International Standard for theProtection of Privacy and Personal Information; they can be obtained by referring to the Codeitself:• Code Article 14 Confidentiality and Reporting

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3.0

Definitions and Interpretation
3.1.

Defined Terms from the Code that are used in the International Standard for theProtection of Privacy and Personal Information
ADAMS: The Anti-Doping Administration and Management System is a Web-based
database management tool for data entry, storage, sharing, and reporting designed to assist
stakeholders and WADA in their anti-doping operations in conjunction with data protection
legislation.
Anti-Doping Activities: Anti-doping Education and information, test distribution planning,
maintenance of a Registered Testing Pool, managing Athlete Biological Passports,
conducting Testing, organizing analysis of Samples, gathering of intelligence and conductof investigations, processing of TUE applications, Results Management, hearings,
monitoring and enforcing compliance with any Consequences imposed, and all otheractivities related to anti-doping to be carried out by or on behalf of an Anti-Doping
Organization, as set out in the Code and/or the International Standards.
Anti-Doping Organization: WADA or a Signatory that is responsible for adopting rules for
initiating, implementing or enforcing any part of the Doping Control process. This includes,for example, the International Olympic Committee, the International Paralympic Committee,
other Major Event Organizations that conduct Testing at their Events, International
Federations, and National Anti-Doping Organizations.
Athlete: Any Person who competes in sport at the international level (as defined by each
International Federation) or the national level (as defined by each National Anti-Doping
Organization). An Anti-Doping Organization has discretion to apply anti-doping rules to an
Athlete who is neither an International-Level Athlete nor a National-Level Athlete, and thus
to bring them within the definition of “Athlete”. In relation to Athletes who are neither
International-Level nor National-Level Athletes, an Anti-Doping Organization may elect to:
conduct limited Testing or no Testing at all; analyze Samples for less than the full menu ofProhibited Substances; require limited or no whereabouts information; or not require
advance TUEs. However, if an Article 2.1, 2.3 or 2.5 anti-doping rule violation is committed
by any Athlete over whom an Anti-Doping Organization has elected to exercise its authority
to test and who competes below the international or national level, then the Consequences
set forth in the Code must be applied. For purposes of Article 2.8 and Article 2.9 and for
purposes of anti-doping information and Education, any Person who participates in sport
under the authority of any Signatory, government, or other sports organization accepting theCode is an Athlete.
[Comment to Athlete: Individuals who participate in sport may fall in one of five categories:
1) International-Level Athlete, 2) National-Level Athlete, 3) individuals who are not
International or National-Level Athletes but over whom the International Federation or
National Anti-Doping Organization has chosen to exercise authority, 4) Recreational Athlete,
and 5) individuals over whom no International Federation or National Anti-Doping
Organization has, or has chosen to, exercise authority. All International and National-Level
Athletes are subject to the anti-doping rules of the Code, with the precise definitions ofinternational and national level sport to be set forth in the anti-doping rules of theInternational Federations and National Anti-Doping Organizations.]

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Athlete Support Personnel: Any coach, trainer, manager, agent, team staff, official,
medical, paramedical personnel, parent or any other Person working with, treating or
assisting an Athlete participating in or preparing for sports competition.
Code: The World Anti-Doping Code.
Competition: A single race, match, game or singular sport contest. For example, abasketball game or the finals of the Olympic 100-meter race in athletics. For stage races
and other sport contests where prizes are awarded on a daily or other interim basis thedistinction between a Competition and an Event will be as provided in the rules of theapplicable International Federation.
Consequences of Anti-Doping Rule Violations (“Consequences”): An Athlete’s or other
Person’s violation of an anti-doping rule may result in one or more of the following: (a)Disqualification means the Athlete’s results in a particular Competition or Event areinvalidated, with all resulting Consequences including forfeiture of any medals, points andprizes; (b) Ineligibility means the Athlete or other Person is barred on account of an antidoping rule violation for a specified period of time from participating in any Competition orother activity or funding as provided in Article 10.14.1; (c) Provisional Suspension means
the Athlete or other Person is barred temporarily from participating in any Competition or
activity prior to the final decision at a hearing conducted under Article 8; (d) Financial
Consequences means a financial sanction imposed for an anti-doping rule violation or torecover costs associated with an anti-doping rule violation; and (e) Public Disclosure means
the dissemination or distribution of information to the general public or Persons beyond
those Persons entitled to earlier notification in accordance with Article 14. Teams in TeamSports may also be subject to Consequences as provided in Article 11.
Delegated Third Parties: Any Person to which an Anti-Doping Organization delegates any
aspect of Doping Control or anti-doping Education programs including, but not limited to,third parties or other Anti-Doping Organizations that conduct Sample collection or other
Doping Control services or anti-doping Educational programs for the Anti-Doping
Organization, or individuals serving as independent contractors who perform Doping Control
services for the Anti-Doping Organization (e.g., non-employee Doping Control officers or
chaperones).
Doping Control: All steps and processes from test distribution planning through to ultimate
disposition of any appeal and the enforcement of Consequences, including all steps andprocesses in between, including but not limited to, Testing, investigations, whereabouts,
TUEs, Sample collection and handling, laboratory analysis, Results Management, hearings
and appeals, and investigations or proceedings relating to violations of Article 10.14 (Status
During Ineligibility or Provisional Suspension).
Education: The process of learning to instill values and develop behaviors that foster andprotect the spirit of sport, and to prevent intentional and unintentional doping.
International Standard: A standard adopted by WADA in support of the Code. Compliancewith an International Standard (as opposed to another alternative standard, practice orprocedure) shall be sufficient to conclude that the procedures addressed by the International
Standard were performed properly. International Standards shall include any Technical
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Documents issued pursuant to the International Standard.
Participant: Any Athlete or Athlete Support Person.
Person: A natural Person or an organization or other entity.
Prohibited Method: Any method so described on the Prohibited List.
Prohibited Substance: Any substance, or class of substances, so described on theProhibited List.
Publicly Disclosed: See Consequences of Anti-Doping Rule Violations above.
Results Management: The process encompassing the timeframe between notification as
per Article 5 of the International Standard for Results Management, or in certain cases (e.g.,
Atypical Finding, Athlete Biological Passport, Whereabouts Failure), such pre-notification
steps expressly provided for in Article 5 of the International Standard for Results
Management, through the charge until the final resolution of the matter, including the end of
the hearing process at first instance or on appeal (if an appeal was lodged).
Sample or Specimen: Any biological material collected for the purposes of Doping Control.
[Comment to Sample or Specimen: It has sometimes been claimed that the collection ofblood Samples violates the tenets of certain religious or cultural groups. It has been
determined that there is no basis for any such claim.]
Signatories: Those entities accepting the Code and agreeing to implement the Code, as
provided in Article 23.
Target Testing: Selection of specific Athletes for Testing based on criteria set forth in theInternational Standard for Testing and Investigations.
Testing: The parts of the Doping Control process involving test distribution planning,
Sample collection, Sample handling, and Sample transport to the laboratory.
Therapeutic Use Exemption [TUE]: A Therapeutic Use Exemption allows an Athlete witha medical condition to use a Prohibited Substance or Prohibited Method, but only if theconditions set out in Article 4.4 and the International Standard for Therapeutic Use
Exemptions are met.
WADA: The World Anti-Doping Agency.
3.2.

Defined Terms from the International Standard for Testing and Investigations
Doping Control Coordinator: An Anti-Doping Organization or a Delegated Third Party thatcoordinates any aspect of Doping Control on behalf of an Anti-Doping Organization. The
Anti-Doping Organization always remains ultimately responsible under the Code forcompliance with the requirements of the International Standard for Testing andInvestigations, Therapeutic Use Exemptions, Protection of Privacy and Personal

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Information, and Results Management.
Doping Control Officer (or DCO): An official who has been trained and authorized by the
Sample Collection Authority to carry out the responsibilities given to DCOs in theInternational Standard for Testing and Investigations.
No Advance Notice Testing: Sample collection that takes place with no advance warning
to the Athlete and where the Athlete is continuously chaperoned from the moment of
notification through Sample provision.
3.3.

Defined Terms Specific to the International Standard for the Protection of Privacy andPersonal Information
Personal Information: Information, including without limitation Sensitive Personal
Information, relating to an identified or identifiable Participant or other Person whose
information is Processed solely in the context of an Anti-Doping Organization’s Anti-Doping
Activities.
[Comment to Personal Information: It is understood that Personal Information includes, but
is not limited to, information relating to an Athlete’s name, date of birth, contact details andsporting affiliations, whereabouts, designated TUEs (if any), anti-doping test results, andResults Management (including disciplinary hearings, appeals and sanctions). Personal
Information also includes personal details and contact information relating to other Persons,such as medical professionals and other Persons working with, treating or assisting an
Athlete in the context of Anti-Doping Activities. Such information remains Personal
Information and is regulated by this International Standard for the entire duration of its
Processing, irrespective of whether the relevant individual remains involved in organized
sport.]
Processing (and its cognates, Process and Processed): Collecting, accessing, retaining,
storing, disclosing, transferring, transmitting, amending, deleting or otherwise making use
of Personal Information.
Security Breach: A breach of security resulting in the loss, theft, damage or unauthorized
and/or unlawful Processing of Personal Information whether in electronic or hard-copy orother form, or interference with an information system, that compromises the privacy,
security, confidentiality, availability or integrity of Personal Information.
Sensitive Personal Information: Personal Information relating to a Participant’s racial or
ethnic origin, commission of offences (criminal or otherwise), health (including information
derived from analyzing an Athlete’s Samples or Specimens) and biometric and genetic
information.
Third Party: Any Person other than the Person to whom the relevant Personal Information
relates, Anti-Doping Organizations, and Third-Party Agents.
Third-Party Agent: Any Person that Processes Personal Information on behalf of, asdelegated by, or as otherwise engaged by an Anti-Doping Organization in the context of

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the Anti-Doping Organization’s own Anti-Doping Activities including, without limitation, aDelegated Third Party and any subcontractors.
3.4.

Interpretation
3.4.1

The official text of the International Standard for the Protection of Privacy andPersonal Information shall be published in English and French. In the event of any
conflict between the English and French versions, the English version shall prevail.

3.4.2

Like the Code, the International Standard for the Protection of Privacy and Personal
Information has been drafted giving consideration to the principles of proportionality,
human rights, and other applicable legal principles. It shall be interpreted and appliedin that light.

3.4.3

The comments annotating various provisions of the International Standard for theProtection of Privacy and Personal Information shall be used to guide its
interpretation.

3.4.4

Unless otherwise specified, references to Sections and Articles are references to
Sections and Articles of the International Standard for the Protection of Privacy andPersonal Information.

3.4.5

The Annexes to the International Standard for the Protection of Privacy and Personal
Information have the same mandatory status as the rest of the International
Standard.

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PART TWO: STANDARDS FOR HANDLING PERSONAL INFORMATION
4.0

Processing Personal Information in Accordance with International Standard and Applicable
Law
4.1 This International Standard sets forth a minimum set of requirements applicable to theProcessing of Personal Information by Anti-Doping Organizations and their Third-Party Agentsin the context of their Anti-Doping Activities. All Anti-Doping Organizations must comply withthis International Standard, even when its requirements exceed those arising under the AntiDoping Organization’s applicable data protection and/or privacy laws, reflecting the vital needto protect the privacy of Participants and other Persons involved in and associated with antidoping in sport.
[Comment to 4.1: Anti-Doping Organizations, along with any Third-Party Agents, minimallymust comply with the requirements set forth in this International Standard, as applicable,
provided that such compliance does not breach other applicable laws. For greater certainty,
in cases where compliance with the requirements of this International Standard may cause an
Anti-Doping Organization to breach other applicable laws, those laws shall prevail. This result
will not lead to a determination of non-compliance with the World Anti-Doping Code to thestrict extent of the conflict, however, Anti-Doping Organizations should communicate any suchconflicts to WADA and other relevant Anti-Doping Organizations as soon as reasonably
possible.]
4.2 Anti-Doping Organizations may be subject to data protection and privacy laws that impose
requirements that exceed those arising under this International Standard. In suchcircumstances, Anti-Doping Organizations must ensure that their Processing of Personal
Information complies with all such data protection and privacy laws.
[Comment to 4.2: Anti-Doping Organizations in certain countries may be subject to laws thatgovern their Processing of Personal Information relating to natural Persons in addition toParticipants, such as their own employees or staff employed by other Anti-Doping
Organizations, or impose additional restrictions going beyond this International Standard. In all
such cases, Anti-Doping Organizations are expected to comply with applicable privacy anddata protection laws.]
4.3 Anti-Doping Organizations shall be able to demonstrate that their Processing of Personal
Information takes place in accordance with this International Standard, in particular throughthe adoption of appropriate internal policies and procedures reflecting their adherence to thisInternational Standard.
[Comment to 4.3: Anti-Doping Organizations can only effectively adhere to the requirementsof this International Standard by having in place documented internal policies, procedures andinformation governance standards relating to Personal Information.]
4.4 Anti-Doping Organizations shall maintain a record of the Processing of Personal Information
for which they are responsible, which shall describe the general purposes of the Processing,a description of the types of Personal Information, the categories of potential recipients of the
Personal Information, the safeguards used where Personal Information is disclosed to otherAnti-Doping Organizations, Third Parties, or Third-Party Agents, the period for which the

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Personal Information will be stored, or the criteria used to determine this period, and a generaldescription of the technical and organizational security measures applied to the Personal
Information.
[Comment to 4.4: Anti-Doping Organizations must maintain a record of their Processing
activities, to better ensure their effective oversight of these activities and to facilitate
compliance with this International Standard. With respect to the ADAMS databaseadministered by WADA, WADA shall be solely responsible for maintaining a record reflecting
the types of Processing of Personal Information that occur within the database.]
4.5 Anti-Doping Organizations shall designate a Person who is accountable for compliance withthis International Standard and all locally applicable privacy and data protection laws. They
shall ensure that the contact information of the Person so designated is made readily available
to Participants in accordance with Article 7.
5.0

Processing Relevant and Proportionate Personal Information
5.1 Anti-Doping Organizations shall only Process Personal Information where relevant andproportionate in order to conduct Anti-Doping Activities under the Code and International
Standards, provided such Processing does not conflict with applicable privacy and dataprotection laws, or where otherwise required by applicable law, regulation or compulsory
legal process.
5.2 Anti-Doping Organizations shall not Process Personal Information that is irrelevant or
unnecessary in the context of their Anti-Doping Activities as identified in Article 5.1.
[Comment to 5.2: Anti-Doping Organizations shall examine the different contexts in which they
Process Personal Information to ensure that the Processing of the Personal Information in any
given case is required in order to satisfy one of the purposes identified in Article 5.1. Where
Anti-Doping Organizations cannot satisfy themselves that the Processing is necessary, theyshall refrain from Processing the Personal Information.]
5.3 In particular, except as otherwise expressly required by law:a) Anti-Doping Organizations Processing Personal Information (which may involve
Processing Sensitive Personal Information relating to Athletes and Processing nonSensitive Personal Information relating to Participants and potentially other Persons) inorder to determine whether an Athlete’s use of a Prohibited Substance or Prohibited
Method is consistent with the provisions of a TUE, shall Process only the Personal
Information proportionate and relevant for making this determination in accordance with
the Code and/or the International Standard for Therapeutic Use Exemptions.
b) Anti-Doping Organizations Processing Personal Information relating to Participants andother Persons in order to perform Testing, shall Process only the Personal Information(including whereabouts information and TUEs) proportionate and relevant for conducting
Testing (e.g., test distribution planning, Sample collection, Sample handling, Sample
transport to the laboratory or associated matters) in accordance with the Code and/or theInternational Standard for Testing and Investigations.

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Page 11 of 24c) Anti-Doping Organizations Processing Personal Information relating to Participants andother Persons in order to engage in investigations and Results Management (including
associated disciplinary hearings, appeals and adjudications) shall Process only the
Personal Information, including but not limited to whereabouts information, TUEs, test
results, and non-analytical intelligence or information, proportionate and relevant forinvestigating and establishing one or more anti-doping rule violations in accordance with
the Code and/or the International Standard for Results Management and the International
Standard for Testing and Investigations.
d) Anti-Doping Organizations may Process Personal Information relating to Participants andother Persons for other specified purposes, provided that those purposes relate exclusively
to the fight against doping and are found to be relevant to that fight following anappropriately documented assessment performed by the Anti-Doping Organization.
[Comment to 5.3.d.: In certain contexts, it may be appropriate or necessary for Anti-Doping
Organizations to Process Personal Information for additional purposes, besides those
identified as Anti-Doping Activities or expressly required by law, in order to engage
effectively in the fight against doping. Such Processing must be exclusively linked to thefight against doping and may only occur where the Anti-Doping Organization has
documented the need to perform such Processing. The general limitations set out in 5.1
and 5.2 continue to apply to any Processing of Personal Information for such purposes.]
5.4 Personal Information Processed by Anti-Doping Organizations shall be Processed fairly andshall be accurate, complete and kept up to date. Anti-Doping Organizations shall correct oramend as soon as possible any Personal Information that they know to be incorrect or
inaccurate, taking into account the responsibilities of Participants to provide accurate and upto-date information regarding themselves to Anti-Doping Organizations, including in thecontext of the provision of whereabouts information.
[Comment to 5.4: Where Participants are responsible for providing Personal Information about
themselves directly to Anti-Doping Organizations and for keeping it accurate, complete and upto-date, they should be informed of this obligation and, whenever practicable, offeredreasonable means to fulfill it. For instance, this could involve furnishing individuals with accessto their Personal Information via the Internet through online tools and resources.]
6.0

Processing Personal Information in Accordance with a Valid Legal Ground
6.1 Anti-Doping Organizations shall only Process Personal Information in accordance with a valid
legal ground, which can include:a) Compliance with legal obligations, performance of a public interest task, where necessary
for reasons of substantial public interest, public health, or fulfillment of a contract, or toprotect the vital interests of the Participant and other Persons; orb) Where permitted, consent of a Participant or other Person, which shall be informed, freely
given, specific and unambiguous, subject to the exceptions in Article 6.2.b, 6.3 and 6.4 ofthis International Standard.
[Comment to 6.1: Principal responsibility for obtaining the consent of an Athlete, and/or his or

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her associated Athlete Support Personnel, or establishing another valid legal ground, shall restwith the Anti-Doping Organization(s) that has the then-primary relationship with the relevant
Participant.]
6.2 Where Anti-Doping Organizations Process Personal Information on the basis of consent(including sharing Personal Information with WADA), Anti-Doping Organizations shall, in orderto obtain an informed, specific and unambiguous consent, ensure that adequate information is
furnished to the Participant or Person to whom the Personal Information relates as described
more fully in Article 7.
a) Anti-Doping Organizations shall inform Participants of the negative Consequences that
could arise from their refusal to participate in Doping Controls, including Testing, and of therefusal to consent to the Processing of Personal Information as required for this purpose.
[Comment to 6.2.a: For the avoidance of doubt, Participants shall be informed that theirrefusal to participate in Doping Controls, when requested to do so, could prevent theircontinued involvement in organized sport and, for Athletes, constitute a violation of theCode and invalidate Competition results, among other things. A Participant who believes
that an Anti-Doping Organization does not comply with this International Standard may
notify WADA pursuant to Article 11.5, which shall, without prejudice to any other rights theParticipant may have under applicable law, consider the grounds for the complaint.]b) Where Anti-Doping Organizations Process Personal Information on the basis of consent(including sharing Personal Information with WADA), Anti-Doping Organizations shallinform Participants that regardless of any refusal to grant or subsequent withdrawal ofconsent, the Processing of their Personal Information by Anti-Doping Organizations still
may be required, unless otherwise prohibited by applicable law, where necessary to enableAnti-Doping Organizations:a) To commence or pursue analyses or investigations involving suspected anti-doping
rule violations relating to the Participant;b) To conduct or participate in proceedings involving suspected anti-doping rule violations
relating to the Participant; orc) To establish, exercise or defend against legal claims relating to an Anti-Doping
Organization and/or the Participant.
[Comment to 6.2.b.: In certain limited circumstances, Anti-Doping Organizations must havethe ability to Process Personal Information in the absence of the Participant’s consent.
These exceptions are necessary to avoid situations where Participants refuse to grantconsent or withdraw consent in order to circumvent anti-doping efforts and procedures
and evade detection for a doping violation.]
6.3 Where Anti-Doping Organizations Process Sensitive Personal Information on the basis ofconsent (including sharing Sensitive Personal Information with WADA), the explicit consent of
the Participant or Person to whom the Personal Information relates shall be obtained. The
Processing of Sensitive Personal Information shall occur in accordance with any specificsafeguards or procedures established under applicable privacy and data protection laws.
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[Comment to 6.3: This International Standard imposes additional restrictions where AntiDoping Organizations Process Sensitive Personal Information, reflecting the greater
sensitivities surrounding the Processing of such information. Specifically, explicit consent
requires a positive, explicit action agreeing to the relevant Processing by the Person to whom
the Personal Information relates. Although the International Standard defines Sensitive
Personal Information to expressly include different classes of information, this is not to suggestthat such information should be Processed by Anti-Doping Organizations, as required by
Article 5.1.]
6.4 In cases where a Participant is incapable of furnishing an informed consent by virtue of age,mental capacity or other legitimate reason recognized in law, the Participant’s legal
representative, guardian or other competent representative may furnish consent on theParticipant’s behalf for purposes of this International Standard, as well as exercise theParticipant’s rights arising under Article 11 below. Anti- Doping Organizations shall ensure thatobtaining consents under such circumstances is permitted by applicable law.
7.0

Ensuring Appropriate Information is Furnished to Participants and Other Persons
7.1 An Anti-Doping Organization shall inform Participants or Persons to whom the Personal
Information relates about the Processing of their Personal Information. This information shall
include:a)

The identity of the Anti-Doping Organization collecting the Personal Information andcontact details of the Person appointed pursuant to Section 4.5;b)Types of Personal Information that may be Processed;c)

The purposes for which the Personal Information may be used;d)Categories of potential recipients of the Personal Information, including Anti-Doping
Organizations (such as WADA), Third Parties and Third-Party Agents who may belocated in other countries where the Participant may compete, train or travel;e)

The possibility and circumstances under which Personal Information may, wherepermitted by applicable law, be Publicly Disclosed (such as the disclosure of test results
and tribunal decisions);f)

The Participant’s rights with respect to the Personal Information under this International
Standard and the means to exercise those rights;

g)

The procedure for submitting complaints pursuant to Article 11.5 and the possibility, if any,
to submit complaints to competent data protection authorities;h)

The period for which the Personal Information will be stored, or the criteria used todetermine this period; andi)

Any other information necessary to ensure that the Processing of Personal Information
remains fair, such as information about regulatory authorities or bodies that oversee theAnti-Doping Organization’s Processing of Personal Information.

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7.2 Anti-Doping Organizations shall communicate the above information to Participants or other
Persons prior to or at the time that they collect Personal Information from Participants or other
Persons in the form and manner specified in Article 7.3; and Anti-Doping Organizations shallbe responsive to the questions or concerns of Participants relating to the Processing of their
Personal Information by the Anti-Doping Organization. Where Anti-Doping Organizations
receive Personal Information from third parties, and not directly from the Participant, they shallcommunicate the above information as soon as possible and without undue delay, unless it
has previously been furnished to the Participant or other Person by other parties. Exceptionally,
notice to the Participant or other Persons may be delayed or suspended where providing such
notice might reasonably be considered to jeopardize an anti-doping investigation or otherwise
undermine the integrity of the anti-doping process. In such cases, the justification for the delay
must be appropriately documented and the information provided to the Participant or other
Persons as soon as reasonably possible.
[Comment to 7.2: Anti-Doping Organizations should recognize that basic principles of fairness
require that where a Participant’s Personal Information is Processed in the context of AntiDoping Activities, he or she should receive or have access to information that explains in simple
terms the purpose and procedures for the Processing of their Personal Information. This
International Standard aspires to ensure that Participants acquire a basic grasp of the roles
and responsibilities performed by the different organizations involved in anti-doping in sport,
as those relate to the Processing of Personal Information. Under no circumstances should AntiDoping Organizations seek to mislead or misinform Participants in order to Process their
Personal Information. In addition to furnishing such information directly to Participants or other
Persons, Anti-Doping Organizations may wish to make such information available on any
websites or other online platforms that they operate.
Each Anti-Doping Organization should ensure that its Processing of Personal Information istransparent to Participants, notwithstanding the fact that certain information relating to AntiDoping Activities, notably information concerning scheduled Testing and investigations andproceedings relating to anti-doping rule violations, may need to be temporarily withheld from
Participants in order to maintain the integrity of the anti-doping process. Similarly, notice toParticipants also may need to be temporarily withheld if providing the information mightreasonably risk jeopardizing an ongoing or reasonably anticipated investigation into dopingrelated activities conducted by an Anti-Doping Organization or law enforcement agencies. The
prompt provision of appropriate information to Participants pursuant to this Article 7 is essential
given the serious adverse Consequences that might arise if Participants are found to havecommitted an anti-doping rule violation.]
7.3 Anti-Doping Organizations shall provide the above information in a manner and format,
whether written, oral or otherwise, that Participants or Persons to whom the Personal
Information relates can easily comprehend, using clear and plain language. Anti-Doping
Organizations shall take into account the age and mental capacity of the Participant or other
Person, as well as local practices, customs and the particular circumstances surrounding theProcessing of the Personal Information.
[Comment to 7.3: Anti-Doping Organizations need to determine the most effective means ofproviding information in particular cases, recognizing that furnishing Participants with written
notice is to be preferred when practical. This also may include furnishing notices throughgenerally available sources, such as brochures and Internet websites, alone or preferably in
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combination with more succinct notices on forms and other documentation provided directly toParticipants. Anti-Doping Organizations also must take into account the specific circumstancesof the Participant or other Person, in particular factors such as their age or mental capacity that
impact their ability to understand the information being presented to them by the Anti-Doping
Organization.]
8.0

Disclosures of Personal Information to other Anti-Doping Organizations and Third Parties
8.1 Anti-Doping Organizations shall not disclose Personal Information to other Anti-Doping
Organizations except where such disclosures are necessary to allow the Anti-Doping
Organizations receiving the Personal Information to fulfill obligations under the Code and theInternational Standards and in accordance with applicable privacy and data protection laws.
[Comment to 8.1: In many instances required by the Code and the International Standards, itis necessary for Anti-Doping Organizations to share certain Personal Information relating toParticipants with other Anti-Doping Organizations so that they may engage in Code-mandated
Testing or otherwise fulfill their respective roles under the Code/International Standards. For
instance, this may occur in order to subject Athletes to In-Competition and Out-of-Competition
Testing. In such cases, Anti-Doping Organizations shall cooperate with one another to ensurethat the participation by Participants in such Testing remains suitably transparent toParticipants and complies with the rules set out in this International Standard and applicablelaws.]
8.2 Anti-Doping Organizations shall not disclose Personal Information to other Anti-Doping
Organizations: (i) where the recipient Anti-Doping Organizations cannot establish a right,
authority or need to obtain the Personal Information; (ii) where there is evidence that therecipient Anti-Doping Organizations do not or cannot comply with this International Standard;(iii) where the Anti-Doping Organization is prohibited from disclosing the Personal Information
by applicable law or restrictions imposed by a competent supervisory authority; or (iv) where
the disclosure would seriously compromise the status of an ongoing investigation into antidoping rule violations. Where an Anti-Doping Organization has concerns that another AntiDoping Organization is incapable of complying with this International Standard, it shall makeits concerns known to the Anti-Doping Organization and WADA as soon as possible.
8.3 Apart from the disclosures referenced in Sections 8.1 and 8.2 above, Anti-Doping
Organizations may disclose Personal Information to Third Parties where such disclosures:a) Are required by law, regulation or compulsory legal process;b) Take place with the informed, express consent of the relevant Participant; orc) Are necessary to assist law enforcement or governmental or other authorities in thedetection, investigation or prosecution of a criminal offence, breach of professional conduct
rules, or breach of the Code; provided that the Personal Information is reasonably relevantto the offence or breach in question and cannot otherwise reasonably be obtained by therelevant authorities.
[Comment to 8.3.c.: The ability of an Anti-Doping Organization to cooperate and exchange
Personal Information with law enforcement agencies and other authorities and the manner

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by which this is to occur may depend upon applicable national laws and regulations. Suchrules may sometimes require or encourage Anti-Doping Organizations to disclose Personal
Information to law enforcement and other authorities when they are aware that thisinformation may be relevant to an investigation. Anti-Doping Organizations must comply
with such national obligations where they exist.]
9.0

Maintaining the Security of Personal Information
9.1 Anti-Doping Organizations shall protect Personal Information that they Process by applying allnecessary security safeguards, including physical, organizational, technical, environmental
and other measures, to prevent a Security Breach.
[Comment to 9.1: Anti-Doping Organizations shall ensure that any access to Personal
Information by their own personnel shall take place on a need-to-know basis only and whereconsistent with assigned roles and responsibilities. Personnel accessing Personal Information
should be informed of the need to hold Personal Information in confidence.]
9.2 Anti-Doping Organizations shall apply security measures that take into account the sensitivityof the Personal Information being Processed. Anti-Doping Organizations shall apply a higher
level of security to the Sensitive Personal Information that they Process, reflecting thecorrespondingly greater risk that a Security Breach involving such information presents to theParticipant or Person to whom the Personal Information relates.
9.3 Anti-Doping Organizations sharing Personal Information with Third-Party Agents in connection
with their Anti-Doping Activities shall ensure that such Third-Party Agents are subject toappropriate controls, including contractual and technical controls, in order to protect theconfidentiality and privacy of the Personal Information and to ensure that the Personal
Information is only Processed on behalf of the Anti-Doping Organization or within the scopeof the delegation or engagement of such Third-Party Agent, as the case may be.
[Comment to 9.3: Anti-Doping Organizations have an ongoing responsibility to protect any
Personal Information under their effective control or in their possession, including Personal
Information Processed by their Third-Party Agents, such as IT-service providers, laboratories,
external experts, Delegated Third Parties, Doping Control Coordinators, and external Doping
Control Officers. Anti-Doping Organizations shall apply contractual controls that can include,
as appropriate, provisions to ensure Third-Party Agents only Process Personal Information on
the documented instructions of the Anti-Doping Organization, subject any Third-Party Agentor its staff handling Personal Information to a duty of confidentiality, apply appropriate technicalsecurity measures and organizational measures to the Personal Information, refrain fromengaging other parties to Process the Personal Information without prior authorization andappropriate contractual controls being in place, require assistance where Participants or other
Persons assert rights under this International Standard or applicable law, delete or return all
Personal Information at the conclusion of the service or upon request, and make information
available to the Anti-Doping Organization to demonstrate compliance with such controls. AntiDoping Organizations shall consider technical controls where Third-Party Agents are granted
access to their systems that include, inter alia, access restrictions and authentication
requirements.]
9.4 Anti-Doping Organizations are required to choose Third-Party Agents that provide sufficient

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guarantees, in accordance with applicable law and this International Standard, in respect of
the technical security measures and organizational measures governing the Processing to be
carried out.
9.5 In the event of a Security Breach, the responsible Anti-Doping Organization shall inform
affected Participants or other natural Persons of the breach, where this breach is likely to affectin a significant way the rights and interests of those Persons concerned. The information must
be provided as soon as reasonably possible once the Anti-Doping Organization becomesaware of the details of the Security Breach and should describe the nature of the breach, thepossible negative consequences for those Persons concerned and the remediation measurestaken or to be taken by the Anti-Doping Organization. Additionally, the Anti-Doping
Organization shall ensure that the Person appointed pursuant to Section 4.5 is also informed
about the Security Breach. The Anti-Doping Organization shall keep a record of Security
Breaches, including the facts relating to the breach, its effects and remedial actions taken.
[Comment to 9.5: Security Breach notification obligations are becoming increasingly common
throughout the world. Pursuant to Article 4 of this International Standard, Anti-Doping
Organizations must comply with national obligations that go beyond the International Standard(i.e., some national regimes may require additional notification to a competent authority orother organizations or impose specific timeframes for notification). A breach does not
significantly affect an individual when the Personal Information in question is subject to suitable
technological protection measures (e.g., encryption) and there is no indication that theprotection has been compromised. Notice shall be given by any appropriate means, whether
written, verbally or otherwise, taking into account the particular circumstances of the Security
Breach, including the prejudice that the relevant Persons may suffer as a result of the Security
Breach.]9.6 Anti-Doping Organizations shall regularly assess their Processing of Sensitive Personal
Information and whereabouts information to determine the proportionality and risks of their
Processing and to assess any measures, including privacy by design measures, that could betaken to reduce the risks for the Participants concerned.
[Comment to 9.6: The requirement to conduct assessments of the Processing of Sensitive
Personal Information and whereabouts information on a regular basis is intended to provide
Anti-Doping Organizations flexibility to conduct such assessments at an appropriate frequency
reflecting applicable privacy and data protection laws, and any changes to such Processing.
For instance, Anti-Doping Organizations have the discretion under the International Standard
for Testing and Investigations to collect varying types and amounts of whereabouts informationfrom different tiers of Athletes. The establishment of appropriate types and amounts of
whereabouts information, as well as any changes to such requirements may require an
assessment].
9.7 Anti-Doping Organizations shall ensure that any staff Processing Personal Information ofParticipants is subject to a fully enforceable contractual and/or statutory duty of confidentiality.
10.0 Retaining Personal Information Where Relevant and Ensuring Its Destruction
10.1

Anti-Doping Organizations shall adhere to those retention times set forth in the latest versionof Annex A - Retention Times attached hereto. Anti-Doping Organizations shall retain any

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Personal Information for which no retention time has been set in Annex A in accordance withthe following principles, and where possible, shall establish clear retention times to govern
their Processing of Personal Information consistent with such principles.
[Comment to 10.1: WADA shall be solely responsible for implementing the retention times
set forth in Annex A within the ADAMS database administered by WADA.]
10.2 As a general rule, retaining Sensitive Personal Information requires stronger or morecompelling reasons and justifications than retaining non-Sensitive Personal Information.
10.3 Anti-Doping Organizations shall ensure that Personal Information is only retained where it
remains relevant to fulfilling their obligations under the Code or under the International
Standards or where otherwise required by applicable law, regulation or compulsory legal
process. Once Personal Information no longer serves the above purposes, it shall be deleted,destroyed or permanently anonymized.
10.4 Anti-Doping Organizations shall develop specific plans and procedures to ensure the secure
retention and eventual destruction of Personal Information.
10.5 Different retention times may be applied to different types of Personal Information and shalltake into account the purposes for which the Personal Information is Processed in the context
of Anti-Doping Activities, including the granting of TUEs, Testing, the investigation of antidoping rule violations, and the sanctioning of such violations.
11.0 Rights of Participants and Other Persons with Respect to Personal Information
11.1 Participants or Persons to whom the Personal Information relates shall have the right to obtainfrom Anti-Doping Organizations: (a) confirmation of whether or not Anti-Doping Organizations
Process Personal Information relating to them, (b) the information as per Article 7.1, and (c) acopy of the relevant Personal Information within one (1) month, where practicable, or as soon
as possible thereafter, in a readily intelligible format, and without excessive cost, subject tolimited exceptions prescribed by law or unless to do so in a particular case plainly conflicts with
the integrity of the anti-doping system or an Anti-Doping Organization’s ability to plan or
conduct No Advance Notice Testing or to investigate and establish anti-doping rule violations
or other legal claims.
[Comment to 11.1: Participants or other Persons may also have additional rights underapplicable privacy and data protection laws, and Anti-Doping Organizations shall follow theprocess set out herein when responding to requests in respect of such additional rights, asapplicable. Principal responsibility for receiving and responding to requests from Participants
or other Persons shall rest with the Anti-Doping Organization(s) that has the then-primary
relationship with the relevant Participant/Person. To the extent it receives any such requests,
WADA will respond in coordination with the relevant Anti-Doping Organization. Save in
exceptional circumstances, (which may include situations where the amount of Personal
Information at issue is significant and involves a disproportionate effort to assemble), an AntiDoping Organization ordinarily is expected to respond no later than four (4) weeks from thedate a properly formulated request is received. Anti-Doping Organizations shall be entitled torequest additional information and clarifications from Participants or Persons in order to be

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able to respond to their request, including, where appropriate, additional information to confirm
the identity of the Participant or Person making the request.]
11.2 Anti-Doping Organizations have to respond to requests from Participants or Persons to whom
the Personal Information relates seeking access to their Personal Information, except if doing
so imposes a disproportionate burden on the Anti-Doping Organizations in terms of cost oreffort given the nature of the Personal Information in question.
11.3 In the event an Anti-Doping Organization refuses to allow a Participant or Person access to
his or her Personal Information, it shall inform the Participant/Person and set out in writing thereasons for refusing the request as soon as practicable. Anti-Doping Organizations shallensure that Participants/Persons only obtain Personal Information relating to themselves, andnot relating to other Participants or third Persons, where they seek to obtain access to
Personal Information pursuant to this Article 11.
11.4 Where an Anti-Doping Organization’s Processing of Personal Information is shown to beinaccurate, incomplete, or excessive, it shall, as appropriate, rectify, amend, block or delete
the relevant Personal Information as soon as possible. If the Anti-Doping Organization has
disclosed the Personal Information in question to another Anti-Doping Organization that to its
knowledge or belief continues to Process the Personal Information, it shall inform that AntiDoping Organization of the change as soon as possible, unless this proves impossible orinvolves a disproportionate effort. The Anti-Doping Organization shall inform the Participant or
Person about these Anti-Doping Organizations where they request the information.
11.5 Without prejudice to any other rights a Participant or Person may have under applicable laws,a Participant or Person shall be entitled to initiate a complaint with an Anti-Doping Organization
where he or she has a reasonable, good-faith belief that an Anti-Doping Organization is notcomplying with this International Standard and each Anti-Doping Organization shall have a
documented procedure in place for dealing with such complaints in a fair and impartial manner.
In the event that the complaint cannot be satisfactorily resolved, the Participant or Person may
notify WADA, which will handle the complaint in accordance with the International Standard for
Code Compliance by Signatories. Where the International Standard for the Protection ofPrivacy and Personal Information is not being adhered to, the relevant Anti-Doping
Organization will be required to resolve the non-conformity in accordance with the International
Standard for Code Compliance by Signatories. Nothing in this International Standard preventsa Participant or Person from lodging a complaint with any competent authority responsible forthe protection of privacy and personal information, and Anti-Doping Organizations shallcooperate with such authorities when investigating the complaint.

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ANNEX A: RETENTION TIMES
ADRV:
AAF:
ATF:
APF:
ATPF:

Anti-doping rule violation
Adverse analytical finding
Atypical finding
Adverse passport finding
Atypical passport finding

I.
II.

Referenced data will be deleted no later than the end of the calendar quarter following the expiry of the stated retention period.
Retention times are limited to two categories: Twelve (12) months and ten (10) years. The period of ten (10) years represents thetime period during which an action may be commenced for an anti-doping violation under the Code. The period of 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.
III. Retention times can be extended in case of pending or reasonably anticipated anti-doping rule violations, investigations, or otherlegal proceedings.
ModuleData

1 – Athlete

Athlete (general)

Retention Periods

Remarks

Criteria:

Athlete data relevant for practical purposes and for notification
purposes in the event of an ADRV. These data are not particularly
sensitive.

Name, Date of birth,Sport Discipline andGender

10 yrs 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), whicheveris 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, mailingaddress)

10 yrs as of time when Athlete is
excluded from ADO’s Testing
programSame as above.

Necessity

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ModuleData

Retention Periods

Remarks

Criteria

2 – Whereabouts**(except for city, country,
and In- Competition
whereabouts information,
which are needed for the
Athlete Biological Passportsee section 7)
Whereabouts

Whereabouts (otherthan city, country and
In-Competition
whereabouts)

12 months as of end of thewhereabouts quarter for which
the data was submitted

Relevant to count 3 whereabouts failures in 12 months’ time.

Necessity

Whereabouts failures(filing failures andmissed tests)

10 years as of date ofwhereabouts failure

Relevant to count 3 whereabouts failures in 12 months’ time and toother possible ADRVs. If ADRV, will also be kept as part of results
management file (see section 6).

Necessity

3 – TUEs

TUE

Destroying medical information makes it impossible for
WADA/ADOs to review TUEs retrospectively after TUE has lostits validity. TUE information is largely medical and therefore
sensitive.
TUE certificates andrejected TUE
decision forms

10 yrs as of date of TUE
expiry/date of rejection decision

Can be relevant in case of re-Testing or other investigations.

Proportionality/ Necessity

TUE application
forms and supp. med
information and anyother TUE info not
otherwise expressly
mentioned herein.

12 months from date of TUE
expiryLoses 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 re-application.

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ModuleData

Retention Periods

Remarks

Criteria

4 – Testing
Testing

Doping Control Forms(DCFs)

10 yrs 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
re-Testing of Samples. If ADRV, will also be kept as part of results
management file (see section 6).

Proportionality/Necessity

Mission/TestingordersRetained until all associatedDCFs have been deletedSame as above.

Proportionality/Necessity

Chain of custody

10 yrs as of document creation
date

Same as above.

Proportionality/Necessity

Incomplete Testing
documentation or
documentation notmatched 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 shortdelay for data integrity purposes.

Proportionality

Necessary because of multiple violations and retrospective analysis.
If ADRV, will also be kept as part of results management file (seesection 6).

Necessity*Subject to the criteria and requirements of the Code/International
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 otherpurposes 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 isthe maximum retention time for identifiable data and Samples. See
the International Standard for Laboratories for details.

Proportionality/Necessity

5 – Test results/Results
Management

As of Sample collection date /date of creation of relevant
documents:
Analytical test results(incl. AAF/ATF),
laboratory reports,
and other associateddocumentation

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10 yrs*Page 23 of 24

ModuleData

6 –Proceedings andDecisions (ADRV)
Decisions andproceedings

Sanctions andDecisions under the
Code

Retention Periods

Remarks

Criteria

As of date of final decision:

Managed by disciplinary body / sports federation / ADO.

Longer of 10 yrs or duration of
sanction*

Necessary because of multiple violations and possible duration of
sanctions.

Necessity* Decisions (e.g. CAS decisions) can be important legal precedents
and part of the public record; in such cases, ADOs may decide toretain a decision beyond the applicable retention period.

Proportionality/Necessity

Relevant
documentation/files(incl. AAF or
whereabouts failure
record, case files,
laboratory and ABP
documentation
packages, etc.)

Longer of 10 yrs or duration of
sanction

Necessary because of multiple violations and possible duration of
sanctions.

Necessity

Results

Biological variables,
ATPF, APF, APMU
reports, expert reviews,
ABP documentation
packages andassociated laboratory
documentation.

10 yrs as of date of match
between results and Doping
Control Form/ date of creation of
relevant documents

Necessary because of multiple violations and to analyze or review
biological variables, APMU reports, expert reviews, etc., over time. If
ADRV, will also be kept as part of results management file (seesection 6).

Necessity

Whereabouts

Whereabouts (only city,
country and InCompetition
whereabouts)

10 yrs as of end of thewhereabouts quarter for which
the data was submitted

Needed to support atypical/abnormal results, or to refute Athletes'
claims.

Proportionality/Necessity

7 – Athlete Biological
Passport

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