During the course of the day-to-day operations of NWB Bank, personal data is processed by and on behalf of the bank. It is important to the bank that your privacy is respected. The bank processes your personal data in accordance with the General Data Protection Regulation (GDPR). As well as these general regulations, specific regulations, such as the Dutch Money Laundering and Terrorist Financing (Prevention) Act, may apply to certain personal data processing operations. This privacy statement tells you what personal data the bank collects and how it is dealt with.
Processing of your personal data
Personal data includes any information that relates to an identified or identifiable individual, such as first name and surname, email address and bank account number. Personal data processing means any operations that NWB Bank or a third party on the bank’s behalf may perform on personal data, e.g. storage, consultation or erasure of personal data. NWB Bank mainly processes personal data of its employees, clients, counterparties, visitors (to our website) and suppliers.
NWB Bank is committed to processing your personal data in accordance with the law. The bank will not process more personal data than is necessary, and your data will not be kept for longer than is necessary for the purposes for which it was collected or is being processed. NWB Bank has determined appropriate retention periods for the various personal data processing operations. On expiry of this deadline, your personal data will be erased. NWB Bank will also ensure that your personal data is correct and updated where necessary. The bank will take suitable technical and organisational measures to protect your personal data and will ensure that your data is treated as confidential.
Purposes of processing
NWB Bank processes your personal data, amongst others, for the purposes below. If your personal data has been provided for a specific purpose, it will not be used for a different purpose.
1. Compliance with statutory obligations
Sometimes NWB Bank is under a statutory obligation to supply your personal data to the government. For example, the bank supplies your first name, surname and IBAN number to the Tax and Customs Administration (Belastingdienst) as part of its annual declaration of the balance of your accounts. NWB Bank erases this data after the statutory seven-year retention requirement.
2. Delivery of products or services to clients
Since all of NWB Bank’s clients are commercial clients, the bank processes personal data of their representatives or contacts on a small scale. For its payment and lending services, the bank processes your first name and surname, and your identity card and IBAN number, where appropriate. NWB Bank also processes Chamber of Commerce extracts, minutes of meetings and, where appropriate, annual reports. These documents may contain personal data relating to you. Your personal data is processed for the purposes of performance of the relevant agreement(s). In principle, NWB Bank will erase this data seven years after the end of the loan or current account agreement or, if you have concluded multiple loan or current account agreements with the bank, after such longer period as is required.
3. Gathering of evidence
If you contact NWB Bank by telephone, the conversation may be recorded and retained for the purpose of gathering evidence for business transactions and identifying suspected fraud. The bank has drawn up regulations for this and the internal audit department checks that these regulations are effective. Your telephone conversation with NWB Bank may be played back under strict conditions. The files containing recorded telephone conversations will be destroyed five years after the calendar month in which they were recorded.
4. Sending of press releases and news reports
NWB Bank uses your email address to send you press releases and news reports. Amongst other things, these keep you up to date with developments within the public sector and the bank, and may include communications relating to payments. The bank will only send you commercial press releases and news reports with your express consent. You can withdraw your consent at any time by using the opt-out facility in the press release or news report concerned. As soon as you indicate that you no longer wish to receive press releases or news reports from NWB Bank, your email address will be removed from the distribution list.
5. Collection of website statistics
NWB Bank uses Google Analytics to collect statistics about the bank’s website, e.g. the most visited pages. We use tracking cookies for this. We also use the information that these cookies collect to find out how we can improve the website. These statistics are anonymous and cannot be traced back to a specific individual or user. We also use this data to provide more targeted information on the website. This allows the bank to further optimise its website services.
6. Recruitment and selection
It is important for NWB Bank to employ honest and reliable people. Screening affects the privacy of the applicant or employee and is therefore only permitted in certain circumstances. The key requirements are that the bank has a legitimate interest and that screening is therefore necessary. The legitimate interest of NWB Bank in pre-employment screening is that the bank must be able to have confidence that the employee is honest and reliable.
The applicant’s personal data is erased within four weeks of the end of the application process. The applicant is notified in advance that screening will take place. You can find more information on this on our website under 'Werken bij de NWB Bank'.
7. Logging of your visit
If you visit NWB Bank’s offices, your first name and surname will be stored in a third-party digital records system and in the bank’s own system so that the bank has a list of the people who are on site, in case the building has to be evacuated. Your personal data will be erased six months after your visit.
Recipients of your data
The following individuals and/or bodies may receive your personal data:
1. Employees of NWB Bank
Employees of NWB Bank may process your personal data for the purposes described above, amongst others. NWB Bank will ensure that your personal data is treated confidentially and with due care at all times.
In the case of certain personal data processing operations, other organisations process personal data on behalf of NWB Bank. The bank concludes a processor agreement with these organisations which contains agreements relating, amongst others, to the security and confidential treatment of your personal data.
In some situations NWB Bank is under a statutory obligation to supply your personal data to the government.
Transfer of your data to third countries and international organisations
In principle, your personal data will not be transferred to countries outside of Europe or to international organisations. In other words: your personal data will only be processed within the European Union . This also applies if other parties process personal data on behalf of NWB Bank. However, MailChimp may be used to send out press releases and news reports. MailChimp’s servers are currently based in the United States.
Under the terms of the GDPR, under certain circumstances, individuals whose personal data is being processed by NWB Bank have the right to receive a copy of their personal data from the bank, to access their personal data, to ask the bank to correct incorrect personal data, to restrict the use of their personal data and to have their personal data erased. These individuals also have the right to object and the right to human intervention in decision-making. In principle, NWB Bank will not charge for the provision of information or for taking measures in this regard, unless your request is unfounded or excessive. If you wish to exercise your rights in this regard, please contact the bank’s privacy officer.
Security of your personal data
NWB Bank must protect the personal data processed within the bank by taking appropriate and organisational measures. NWB Bank has implemented the ISO 27002 standards for information security. Employees of the bank and external employees can only access the information that they need to carry out their duties. Additional measures have been taken in respect of certain personal data processing operations in view of the sensitive nature of the data concerned.
Record of processing activities
NWB Bank maintains a record of processing activities that contains the bank’s key business processes.
Profiling is the term used for any form of automated processing of personal data that aims to analyse or predict personal aspects of an individual for commercial purposes, for example in order to provide targeted advertisements. NWB Bank does not engage in profiling activities.
This Privacy Statement does not apply to third-party websites that are linked to our website through hyperlinks or references.
Changes to the Privacy Statement
NWB Bank reserves the right to make changes to this Privacy Statement from time to time. It is important therefore that you review the Privacy Statement on a regular basis.
If you have a complaint about the processing of your personal data by or on behalf of NWB Bank, please contact your account manager or the privacy officer. You may also submit a complaint to one of the following bodies:
- your local legal advice centre (juridisch loket);
- your legal aid insurer (rechtsbijstandsverzekeraar);
- the courts.
You can also submit a complaint to the Dutch Data Protection Authority (Autoriteit Persoonsgegevens). For more information on this matter, please see the Dutch DPA’s website.
Contact details of the privacy officer
NWB Bank has appointed a privacy officer, who ensures that the bank applies and complies with the provisions of the GDPR and other applicable privacy legislation and regulations. If you have a query relating to the Privacy Statement, please contact the privacy officer. Her contact details are as follows:
Name: Caroline Pels
Telephone number: +31 70 416 62 53
Email address: firstname.lastname@example.org
Address for visitors: Rooseveltplantsoen 3, 2517 KR, The Hague
To read or download directions to the bank’s address, click here.
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Date: 25 May 2018