International Standard for Classification Data Protection
September 2016

International Paralympic Committee
Adenauerallee 212-214
53113 Bonn, Germany

Tel. +49 228 2097-200
Fax +49 228 2097-209

www.paralympic.org
info@paralympic.org

Introduction
The fundamental purpose of the IPC Athlete Classification Code (the Code) is to uphold
confidence in Classification and advance participation by a wide range of Athletes. To achieve
this purpose, the Code details policies and procedures common across all sports and setsprinciples to be applied by all Para sports.
The Code is complemented by International Standards that provide technical and operational
standards for specific aspects of Classification to be carried out by all Signatories in a manner
which Athletes and other Paralympic stakeholders understand and have confidence in.
Compliance with these International Standards is mandatory. This International Standard forClassification Data Protection must be read in conjunction with the Code and the otherInternational Standards.

PurposeThe Code requires Athletes to supply Classification Data to Classification Organisations.
Athletes can also consent to the supply of certain additional data to assist Classification
Organisations develop Classification. The purpose of the International Standard forClassification Data Protection is to ensure that Classification Organisations use Classification
Data consistently in accordance with their legal obligations.

Definitions
This International Standard uses the defined terms in the Code and other InternationalStandards. Further defined terms specific to this International Standard are as follows:
Classification Data: Personal Information and/or Sensitive Personal Information provided by
an Athlete and/or a National Body and/or a National Paralympic Committee and/or any otherperson to a Classification Organisation in connection with Classification.
Classification Organisation: any organisation that conducts the process of Athlete
Evaluation and allocates Sport Classes and/or holds Classification Data.
National Laws: the national data protection and privacy laws, regulations and policies
applicable to a Classification Organisation.
Personal Information: any information that refers to, or relates directly to, an Athlete.

International Standard for Classification Data Protection – September 20162

Process/Processing: the collection, recording, storage, use or disclosure of PersonalInformation and/or sensitive Personal Information.
Research Purposes: research into matters pertaining to the development of sports within
the Paralympic Movement, including the impact of Impairment on the fundamental activities
in each specific sport and the impact of assistive technology on such activities.

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11.1

General Provision
Classification Organisations must comply with this International Standard regardless oftheir applicable National Laws.

[Comment to Article 1: This International Standard imposes a minimum standard of data protection thatall Athletes can expect when being classified regardless of where the Athlete concerned is classified. If aClassification Organisation operates in a country that has data protection laws that include requirementsthat exceed those set out in this International Standard, the Classification Organisation must comply withboth this International Standard and those higher national obligations.]

2Classification Data that can be Processed

2.1

Classification Organisations may only Process Classification Data if such Classification
Data is considered necessary to conduct Classification.

2.2

All Classification Data Processed by Classification Organisations must be accurate,complete and kept up-to-date.

[Comment to Article 2: Given the personal and sensitive nature of Classification Data, Classification
Organisations must be cautious when Processing it. If a Classification Organisation is not sure if theClassification Data submitted by an Athlete is necessary to conduct Classification it must not Processthat Classification Data.]33.1

Consent and Processing
Subject to Article 3.3, Classification Organisations may only Process Classification Datawith the consent of the Athlete to whom that Classification Data relates.

[Comment to Article 3.1: Athlete consent is usually provided by the Athlete signing an Athlete Evaluationconsent form, International Sport Federation Eligibility Code Form or other agreement.]

3.2

If an Athlete cannot provide consent (for example because the Athlete is under age) thelegal representative, guardian or other competent representative of that Athlete must
give consent on their behalf.

[Comment to Article 3.2: A ‘competent representative’ of an Athlete may be a member of that Athlete’sdelegation if the Athlete’s legal representative or guardian has expressly agreed to this.]

3.3

Classification Organisations may only Process Classification Data without consent of therelevant Athlete if permitted to do so in accordance with the National Laws of therelevant Classification Organisation.

International Standard for Classification Data Protection – September 20164

[Comment to Article 3.3: There may be instances where the Processing of Classification Data without
consent is necessary. One example could be in the context of an investigation into potential misconduct
by an Athlete. In such instances, Classification Organisations must take care to ensure all Processing ofClassification Data without consent is consistent with the relevant National Laws.]

4Provisions that apply to Classification Research

4.1

Classification Organisations may request that an Athlete provide them with Personal
Information and/or sensitive Personal Information for Research Purposes.

4.2

The use by Classification Organisations of Personal Information and/or sensitive
Personal Information for Research Purposes must be consistent with this International
Standard and all applicable ethical use requirements, including, but not limited to,those that apply to the Classification Organisation.

4.3

Personal Information and/or sensitive Personal Information that has been provided by
an Athlete to Classification Organisations solely and exclusively for Research Purposesmust not be used by that Classification Organisation for any other purpose.

4.4

Classification Organisations may only use Classification Data for Research Purposeswith the express consent of the relevant Athlete. If Classification Organisations want topublish any Personal Information and/or sensitive Personal Information provided by anAthlete for Research Purposes, it must obtain consent to do so from that Athlete prior
to any publication. This restriction does not apply if the publication is anonymised sothat it does not identify any Athlete(s) who consented to the use of their Personal
Information and/or sensitive Personal Information.

[Comment to Article 4: Research is vital for the development of Classification in sport and Athletes will be
asked to provide Classification Data to Classification Organisations. Any such use must comply with thisInternational Standard and, in particular, any Personal Information and/or sensitive Personal Information
provided in connection with Research Purposes must not be used in relation to Athlete Evaluation and theallocation of a Sport Class.]

5Notification to Athletes

5.1
5.1.1

Classification Organisations must notify an Athlete who provides Classification Data as
to:the identity of the Classification Organisation collecting the Classification Data;
andInternational Standard for Classification Data Protection – September 20165

5.1.2the purpose for the collection of the Classification Data; and5.1.3

the duration that the Classification Data will be retained.

[Comment to Article 5.1: Classification Organisations can decide the most effective way of notifying
Athletes. This may be in the form of notices communicated to Athletes via websites or social media or via
standard forms and templates used in Classification. Individual or personalised notification is notrequired.]

6Classification Data Security

6.1

Classification Organisations must:

6.1.1

protect Classification Data by applying appropriate security safeguards, including
physical, organisational, technical and other measures to prevent the loss, theft or
unauthorised access, destruction, use, modification or disclosure of Classification
Data; and

6.1.2

take reasonable steps to ensure that any other party provided with Classification
Data uses that Classification Data in a manner consistent with this InternationalStandard.

77.1

Disclosures of Classification DataClassification Organisations must not disclose Classification Data to other Classification
Organisations except where such disclosure is related to Classification conducted byanother Classification Organisation and the disclosure is consistent with all applicable
National Laws.

[Comment to Article 7.1: A Classification Organisation may wish to exchange Classification related
information with another Classification Organisation, especially in connection with Competitions. Thismay only take place if the Classification Organisation receiving the information complies with thisInternational Standard. Most International Sport Federation Athlete consent forms include the possibilityof such an exchange. If not, it is recommended that such consent forms are revised to include theconsent for exchange of Classification information.]
7.2

Classification Organisations may disclose Classification Data to other parties only ifsuch disclosure is in accordance with this International Standard and permitted byNational Laws.

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[Comment to Article 7.2: If a Classification Organisation shares Personal Information with another party,
such as a Major Competition Organiser, it may only do so if either the Athlete concerned has consented inadvance (for example by agreeing to this as part of the Competition entry conditions) or if the Processing
is permitted under the applicable National Laws.]

8Retaining Classification Data

8.1

Classification Organisations must ensure that Classification Data is only retained for as
long as it is needed for the purpose it was collected. If Classification Data is no longer
necessary for Classification purposes, it must be deleted, destroyed or permanentlyanonymised.

8.2

Classification Organisations must develop and publish guidelines regarding retention
times in relation to Classification Data.

[Comment to Article 8.2: Classification Organisations may retain Classification Data as long as there is aClassification need for that data. Classification Organisations must develop guidelines and practices inrespect of data retention that are clear and comprehensible. These must include clear policies regarding
the retention of Classification Data in respect of Athletes who retire from a sport.]

8.3

Classification Organisations must implement policies and procedures that ensure thatClassifiers and Classification Personnel retain Classification Data for only as long as isnecessary in order for them to carry out their Classification duties in relation to anAthlete.

[Comment to Article 8.3: Athletes provide a significant amount of Classification Data for Athletes to beallocated a Sport Class. This Classification Data will be provided to Classifiers appointed by theClassification Organisation responsible for Athlete Evaluation. That Classification Organisation must
make sure that individual Classifiers only use this Classification Data in connection with their role asClassifiers, and in particular, do not themselves retain any of the Classification Data after Athlete
Evaluation is completed. This includes any notes, comments, video recordings or records written orcaptured electronically, generated or compiled by Classifiers during Athlete Evaluation. For example,Classifiers must not have Classification data saved on personnel laptops or other storage devices. Anysuch data can be retained by the Classification Organisation if that retention is consistent with this Article
8.]

99.1

Access Rights to Classification Data
Athletes may request from a Classification Organisation:

International Standard for Classification Data Protection – September 201679.1.1

confirmation of whether or not that Classification Organisation Processes
Classification Data relating to them personally and a description of theClassification Data that is held;

9.1.2

a copy of the Classification Data held by the Classification Organisation; and/or9.1.3

correction or deletion of the Classification Data held by the Classification
Organisation.

9.2

A request made pursuant to Article 9.1 may be made by an Athlete or a National Body
or National Paralympic Committee on an Athlete’s behalf and must be complied withwithin a reasonable period of time.

[Comment to Article 9.1: Classification Organisations must be able to provide Athletes with details of theClassification Data they have used as part of Classification. Generally a Classification Organisation should
respond to such an ‘access request’ as soon as is practicable.]International Standard for Classification Data Protection – September 20168