Privacy policy

The General Data Protection Regulation (hereinafter: GDPR) has been in force to regulate personal data processing since 25 May 2018. In the role of your employer, Nedco B.V., hereinafter referred to as Nedco, processes your personal data acting as controller. Nedco respects your privacy and takes care that your personal data will be processed in accordance with legislation and regulations. In this privacy policy, Nedco informs you about several topics relating to processing your personal data.

Contact details controller

This privacy policy applies to processing performed by Nedco.

Company data
Name: Nedco B.V.
Physical and postal address: ’s-Gravenweg 346, 2911HA Nieuwerkerk aan den IJssel
Chamber of Commerce number: 29050322
General phone number: 0180-317199
General e-mail address: info@nedco.nl
Website: www.nedco.nl

Nedco has not appointed a data protection officer. If you have any questions, or if you want to exercise your individual rights, you can contact Nedco’s privacy contact person. Nedco will answer your message within a month.

Privacy contact data
Contact person: J. Nederlof
E-mail address: jnederlof@nedco.nl
Phone number: 0180317199

Processed personal data

In the context of the employment relationship, Nedco processes several personal data. The personal data of employees which Nedco processes include amongst others:

Citizen service number;
First and last name;
Address details;
Gender;
Date of birth;
E-mail address(es);
Phone number(s);
Bank account number;
Whether you have a partner and their data, if there is a partner’s pension;
Whether you have children and their data, if there is an orphan’s pension;
Licence plate number;
Profile picture;
Camera images;

Nedco has collected these personal data from you personally. If Nedco intends to acquire personal data of you via a third party, you will be extra informed by Nedco according to the applicable laws and regulations.

Processing purposes

Nedco collects your personal data primarily to be able to implement – in its widest sense – the employment contract that Nedco has concluded with you. Processing takes place particularly in personnel administration, absence registration, ICT systems and payroll administration.

The purposes of Nedco processing your personal data are as follows:

To contact you and to stay in contact (by post, phone, e-mail);
To run correct personnel administration, wage administration and internal management.
To meet the obligations we have as an employer resulting from the employment relationship, like paying your salary, issuing pay slips and annual statements, procuring participation in a pension scheme and/or taking out any necessary insurance.
To meet the legal obligations we have as an employer, like obligations regarding absence and reintegration, tax payment, correct salary payment, participation in a mandatory industry-wide pension plan; or considering our ability to request and obtain possible benefits;
To be able to provide access to sites, buildings and rooms of Nedco;
To inform you about developments within Nedco;
For marketing ends;
To guarantee your safety and that of other persons and goods.

Nedco processes the acquired personal data only for above purposes. If Nedco intends to process your personal data for other purposes, Nedco will contact you to give you the opportunity to object to further processing. This will take place before any possible further processing, and information about this other purpose and all further relevant information will be shared with you during this consultation.

Legal grounds for processing

Processing as part of the aforementioned purposes always has at least one legal ground. These legal grounds are explained below.

Implementation of (employment) agreement
In many cases, Nedco processes your personal data to implement your employment agreement.

Meeting legal obligations
In many cases, Nedco processes your personal data to be able to meet a legal obligation incumbent upon Nedco.

Balance of interests
Furthermore, processing your personal data is sometimes necessary for the representation of the legitimate interests of Nedco or of any third party. In that situation, Nedco assesses whether your interests and fundamental rights outbalance those legitimate interests. Only if that is not the case, Nedco processes your personal data based on the balance of interests ground.

In case processing your personal data is based on the legal ground of balance of interests, Nedco will inform you about this and specify the relevant legitimate interests.

Consent
In principle, as an employer Nedco will not (only) base any processing of your personal data on your consent. For processing based on your consent, you would namely be required to give free, explicit, unambiguous consent. Because an employer-employee relationship exists between Nedco and you, it is assumed that in most cases you cannot give your consent in full freedom. This assumption knows exceptions: if Nedco provides additional safeguards to ensure you can consent or reject in full freedom, without the risk of being impaired, free consent can still be realised. In that case, Nedco can base processing on your consent. If this situation occurs, you will be informed about this beforehand.

If Nedco processes personal data on the ground of your consent, you are always entitled to withdraw this consent. If processing takes place exclusively on the ground of your consent, no further processing may be performed after the withdrawal of your consent. Withdrawing consent shall not affect the legitimacy of any consent-based processing performed before the withdrawal.

Consequences of withholding personal data

Nedco will inform you beforehand about any situations in which you will be required to provide personal data which subsequently have to be processed by the Finance/HR departments on the grounds of:

A legal or contractual obligation and/or;
This being a necessary condition for concluding an agreement.

In that case, you will also be informed about the ensuing consequences if you might refuse to provide these personal data. In general, Nedco can – in case you refuse to provide certain personal data – draw any consequences they deem appropriate in the particular situation.

Retention period

Concerning your personnel file specifically, Nedco will retain this file – as advised by the Data Protection Authority – up to two years after the end of your employment agreement. This term can be shorter or longer in individual cases, if the data concerned are no longer relevant, or are indeed relevant for a longer time.

Data from our payroll administration that are fiscally relevant are retained by Nedco – in compliance with the legal retention period – up to seven years after your resignation.

Nedco retains income tax declarations and a copy of your identity document, in compliance with the Wages Tax Act 1964, up to 5 years after the end of your employment agreement.

For retaining any other personal data, no legally or internally pre-set periods apply. Nedco applies the principle that your personal data should no longer be retained than strictly necessary for the purposes your personal data were collected for. Whenever your personal data are no longer relevant for the purposes mentioned, Nedco will delete them.

Recipients of personal data

Nedco exchanges your personal data with third parties. This concerns, among others, the following recipients:

The accountant Visser & Visser;
The absenteeism insurer Avéro Achmea via intermediary Raetsheren van Orden B.V.;
The pension insurer or the pension fund Scildon;
The Dutch Tax Administration;
The Employee Insurance Agency Netherlands;
The health and safety service ArboNed;

In case any of the aforesaid parties takes the role of processor, Nedco will conclude a data processing agreement with them in order to safeguard the protection of your data.

Transfer of personal data to a third country outside the European Union

Personal data are not processed in countries outside the European Union.

Your rights

Based on the GDPR, you are entitled to several rights concerning your personal data:

The right of access;
The right to rectification;
The right to erasure;
The right to restriction of processing;
The right to object to processing;
The right to data portability;
The right not to be subject to automated decision-making.

In case you want to exercise your rights, you can submit a request via the contact details mentioned in this letter. Note: the rights mentioned above are not absolute. I.e. Nedco is not always obliged to grant a request for exercise of one of the rights mentioned above.

Nedco will inform you within a month after Nedco has received your request for exercise of one of the aforementioned rights. In doing so, Nedco will communicate whether and how your request will be granted, and if not, why not. Provided that this is necessary in consideration of the request, Nedco can extend the month-long response term. In that case, Nedco will inform you within one month about the term within which they will reply. Exercising your right(s) will in principle be free of charge.

Filing a complaint with the supervisor

It is possible that, despite Nedco’s prudent approach, you have a complaint about the way in which Nedco processes your personal data and/or respects your rights. In that event, you can file a complaint with the supervisor. In the Netherlands, the Data Protection Authority is supervisor in the field of personal data processing. You will find the contact details of the Data Protection Authority via the website www.autoriteitpersoonsgegevens.nl.

Modifications

The privacy policy as worded here was drawn up on 31 May 2022 and may be modified. Nedco has the right to do so. Any modification of the privacy policy will be communicated to you by e-mail in a timely manner. We also advise you to periodically check the privacy policy for any possible modifications.

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