Who are we?

We are De Integriteitscoördinator BV, sometimes also trading as The Integrity Coordinator. Our mission is to promote ethical and compliant business. Our core business is coordinating speak-up or whistleblowing procedures. Our clients appoint us to receive and follow up on whistleblower reports. We also provide training and advice on this. In doing so, we process personal data.

Our contact details are:

• e-mail: info@deintegriteitscoordinator.nl
• telephone: +31-10-2134580
• website: www.deintegriteitscoordinator.nl / www.theintegritycoordinator.com
• address: Erasmus Enterprise N5-09, Burg. Oudlaan 50, 3062 PA Rotterdam, The Netherlands
• Registration nr: 78450810 (Chamber of Commerce)

Why this statement?

We are responsible for protecting your personal data to the best of our ability. In doing so, we must comply with the requirements of the general data protection regulation. We are transparent about the types of data we process, the purposes for processing, with whom we share data and the rights you have regarding your own data. In this privacy statement, we inform you about this. Do you still have questions after reading this document? Then please contact us.

1. Types of data

1.1 We (possibly) process the following personal data:

• contact data, such as name, address, place of residence, telephone number, e-mail address, employer and position;
• age, gender, marital status;
• data relating to passport, driving license or other proof of identity;
• data relating to employment, income and bank accounts (employees only);
• special personal data, e.g. health data (in some cases);
• data relating to any criminal offences, fraud aspects (if relevant);
• other due diligence or investigative data (if relevant).

1.2 When we process health or criminal data, we do so with extreme care, and usually only with your consent. Generally, you provide us with this data yourself of your own free will.

2. Purposes of data processing

2.1 We process personal data when we receive (whistleblower) reports and when we assess and follow up on them. In that case we process data with the purpose of:

• executing an agreement

2.2 We also process personal data in the performance of our other activities, for the following purposes:

• managing our relationship with (potential) customers;
• managing and expanding our customer base;
• concluding and executing agreements;
• assessing business partners of ourselves and our clients;
• performing marketing activities
• performing a statutory duty
• complying with legal obligations;
• sending newsletters or information of a specific nature.

3. Legal grounds for processing data

3.1 We use at least one of the following grounds for processing your personal data:

• the execution of an agreement;
• being able to comply with a legal obligation;
• complying with statutory data retention periods;
• the explicit consent you have given us to process data for specific purposes. You can withdraw this consent at any time;
• for safeguarding our legitimate interests within the framework of our business operations or those of third parties, like our clients. In doing so, we always weigh up your interests, those of our customers and ours.

4. Storage and retention period of personal data

4.1 We store your personal data only for as long as and to the extent that we need it.

5. Information, amendment and objection

5.1 You have specific rights regarding the processing of your personal data.

5.2 This certainly includes the following:

• whether we process your personal data;
• the way we process your personal data;
• access to the personal data we process about you;
• objections to the processing of your personal data;
• amendment of your personal data if they have been (possibly) incorrectly processed;
• limitation of your personal data;
• deletion (erasure) of your personal data;
• transfer of your personal data to yourself or to another organisation at your request;
• questions about the content of this privacy statement

Send an e-mail to info@deintegriteitscoordinator.nl if you want to exercise one of these rights.

5.4 Please note that we may not be able to accommodate a request in all cases. If this is the case, we will let you know.

There may also be costs associated with your request which we will specify in advance and which can never exceed the costs permitted by applicable regulations.

In order to comply with your request, we will have to establish your identity to prevent others from obtaining access to your data or from unintentionally changing or deleting your data.

6. Security of your data

6.1 We have taken adequate technical and organisational measures to secure your personal data. We use measures that can reasonably be expected of us based on the state of the art of the technology.

7.  Provision of data to third parties

7.1  We won’t provide your personal data to others for no obvious reason. However, we may do so if you have given us permission to do so, if we are obliged to do so on the basis of legislation, regulations or a court ruling, or if the provision serves our purposes for processing personal data.

7.2 In order to conduct our business and depending on the services provided to you, we may provide your personal data to the following persons or parties:

• clients with whom we have concluded a contract to coordinate speak-up or whistleblowing procedures, subject to your consent;
• investigators whose role is to verify the accuracy of a report. We will only pass on your details to investigators who have the required licences;
• Providers of whistleblowing software;
• Persons and bodies who need to be informed by virtue of a legal obligation;
• External parties processing data under our control and responsibility;
• Notaries, lawyers, accountants (where appropriate) and our tax advisor.

7.3 External parties who process personal data under our responsibility only doing so for purposes and under the conditions that we have agreed with them. We record this in written agreements.

8. Changes to the privacy statement

8.1 We may amend this privacy statement in the future. You will always find the most up-to-date privacy statement on our website.

9. Right to complain

9.1 Do you disagree with the way we process your personal data or deal with your rights as a customer? If so, please contact us in any case via info@deintegriteitscoordinator.nl.

9.2 You can also submit a complaint to the Data Privacy Authority (de Autoriteit Persoonsgegevens). To do so, please visit www.autoriteitpersoonsgegevens.nl.

10. Cookies

The protection of your personal data is important to us. That is why we do not install any cookies on our websites. Should you nevertheless encounter a cookie on our website(s), please inform us.