Version: September 2024

UBN Uitzendbureau BV and UBN Flex BV (hereinafter: “UBN” and also “we” and “us”), with its registered office and principal place of business at (3721 BA) Bilthoven at Leyenseweg 1, registered in the Commercial Register of the Chamber of Commerce under number 30148921, has various clients to whom it provides its employees. UBN also provides services in the field of recruitment and selection. In order to provide our services, it is necessary for us to process your personal data. We place great value on your privacy and therefore adhere to the rules arising from privacy laws and regulations. Through this privacy statement, we aim to provide you with clarity on what we do with the personal data you provide to us.

Application

This privacy statement applies to:

• prospective employees who have registered as job seekers with UBN, as well as employees, interns, and other individuals working at UBN (including self-employed individuals) who are assigned to clients through UBN;
• (in-house) UBN employees who are not assigned to clients;
• all visitors to our website;
• employees or representatives of our (potential) business partners (including UBN’s suppliers and clients).

Purposes and legal basis for the processing of personal data of (prospective) employees

UBN processes personal data for the following purposes:

• An assessment of your suitability and availability for job placement;
• Your path to employment;
• Establishing an employment relationship and the related administrative procedures;
• Maintaining the employment relationship and managing personnel and payroll administration;
• The performance of the employment contract between you and UBN;
• Entering into and performing the agreement between UBN and our clients;
• To inform you about our services;
• Quality and management purposes, such as audits, financial audits, and certifications;
• Promoting your personal development, for example through training programs;
• Fulfilling our reintegration obligations;
• Applying for grants, premium discounts, etc.;
• To comply with the legal obligations imposed on UBN;
• Answering your questions;
• Compliance with a court order or judgment.

Personal data will only be processed if one of the legal grounds is met.

• Most processing of personal data is carried out because it is necessary for the performance of a contract to which you are a party.
• Personal data is also processed to comply with a legal obligation imposed on UBN, such as providing personal data to the tax authorities under the Wage Tax Act or processing personal data in connection with the Gatekeeper Improvement Act.
• In some cases, processing is necessary to protect the legitimate interests of UBN or a third party, unless your interests or fundamental rights and freedoms outweigh the interests of UBN and/or the third party.
• When (prospective) employees upload a passport photo themselves via My UBN, that photo will be processed.
• Questions submitted via web forms or surveys.

Registration with UBN and job placement services

When you register, we ask that you provide us with the following personal information:

• Personal information
• Phone number
• Email address
• Date of birth
• What education, work experience, and certifications you have
• Whether you hold a driver's license (if and to the extent relevant to the Function)
• Availability and desired salary
• Gender
• A copy of your ID (including the information listed on it, such as your Social Security number, passport photo, and nationality)
• Copy of residence permit or work permit (if applicable)
• Bank account number

If you choose to provide us with your curriculum vitae (hereinafter: “CV”) when registering, you may include the following information: name (initials, first names, last name, nickname), address, phone number, email address, desired professions/positions, work experience, education, courses, and skills. We advise against including any information other than this in your CV.

If Function medical fitness requirements apply to a particular Function , UBN may, in certain situations, request a medical examination to assess your medical fitness for the Function. The results of that examination (but not the medical information itself) will be provided to UBN by the company physician only after you have given your consent.

If a Certificate of Good Conduct (VOG) is required for the (desired) Function, UBN is authorized to record in its records that a VOG has been issued. If a VOG is not issued, UBN will not record this in its records.

You are not required to provide UBN with any information about your health unless it is directly relevant to the performance of the Function you are applying. However, you are required to disclose any health conditions that you know or should understand render you unsuitable for the Function.

Disclosure of personal data to the client

Provided it is consistent with the purpose for which you provided your personal data to UBN, UBN is permitted to disclose your personal data to potential clients. UBN will not disclose more data than is necessary for the purposes for which you provided your personal data to UBN. This includes the following personal data: name, place of residence, date of birth, email address, phone number, education, work experience (if and to the extent relevant to the Function), courses (if and to the extent relevant to the Function), and other information related to your work experience (if and to the extent relevant to the Function)

If and to the extent that it is relevant to the Function , UBN Function also provide the following information to potential clients: whether you hold a driver’s license, or whether a Certificate of Good Conduct (VOG) has been issued to you. If no VOG has been issued, we will not disclose this information to the potential client. If a medical examination is required: whether you are (based on the medical examination) suitable for the Function.

When you start working for a UBN client, UBN may also provide the client with your Social Security number and the number on your ID, as well as a copy of your residence permit, if applicable.

Self-employed individuals

For self-employed individuals, UBN also processes the following information: bank account number, Chamber of Commerce registration number, extract from the Chamber of Commerce Trade Register, copy of liability insurance (regarding the company’s liability), and VAT number. No copy of an ID card or Social Security Number (BSN) is provided. However, if the self-employed person is from a non-EEA country (all EU countries plus Liechtenstein, Norway, and Iceland), a copy of their ID is processed. Finally, a copy of a residence permit or work permit is processed if applicable.

During the employment contract

During the term of the employment contract, UBN is permitted to process certain personal data about you in your personnel file. This includes, among other things, complaints, warnings, personal performance notes from your supervisor, vacation entitlements, and correspondence regarding your performance. UBN is permitted (whether or not required) to process certain personal data about you for payroll administration purposes. This includes, among other things, pay stubs, wage garnishments, pension data, annual statements, and a payroll tax statement. In the event of a sick leave report, UBN may process certain personal data about you, such as: your home or hospital address, the expected duration of your absence, current appointments and work activities, and whether you fall under one of the safety net provisions of the Sickness Benefits Act (but not which specific provision). After consulting the company physician, the following information is processed, among other things: which tasks you are no longer able to perform or are still able to perform, and any recommendations regarding adjustments, workplace accommodations, or interventions that UBN must implement for your reintegration.

There may be situations in which it is necessary to provide certain personal data about you in order to protect the legitimate interests of UBN or those of the client. This may be the case, for example, if specific reintegration activities need to be carried out in connection with your reintegration.

Disclosure of personal data to parties other than clients

UBN may disclose your personal data to third parties if this is consistent with the stated purposes and legal bases, including suppliers, audit bodies, government agencies, and companies and/or individuals that UBN has engaged to perform certain tasks (including processors).

Retention periods

Your personal data will be retained for as long as necessary to fulfill the purposes for which it was collected. After the (statutory) retention period, your personal data will be destroyed. If you have not been employed by UBN, UBN will not retain your personal data for longer than one year in any case. If a copy of your identification document was made upon your registration, UBN will retain this copy until it is no longer necessary. UBN will destroy the copy no later than four weeks after it has been included in UBN’s records, unless you have entered into an employment contract with UBN during that four-week period. As soon as you notify UBN that you no longer wish to be placed in employment, UBN will immediately remove all your personal data from its system. If an employment contract (or other type of employment relationship) has been established between you and UBN and has been terminated, UBN will not retain your personal data for longer than two years, unless UBN is subject to a legal obligation to retain the personal data for a longer period. A longer (legal) retention obligation applies to UBN (in any case) in the following situations:

1. Personal data related to your health may be retained for longer than two years if there is a labor dispute or a dispute regarding the award of disability benefits. The relevant data will be deleted once the dispute has been resolved.
2. UBN retains all personal data contained in the payroll records for a period of seven years.
3. The payroll tax form you completed (specifically, the document in which you indicated whether or not UBN should take the payroll tax credit into account), a copy of your ID, your full name, date of birth, Social Security number, address with ZIP code, city of residence, and—if you do not live in the Netherlands—your country and region of residence will be retained for five years.

If a return-to-work file was created during your employment—in the event of a long-term illness—and was closed during your employment, UBN generally retains this return-to-work file for no longer than two years (after the return-to-work process is completed). Administrative data regarding your sick leave (such as information related to the obligation to continue paying wages, the date of the sick leave notification, the duration of the absence, and the date of recovery) will generally be retained for a maximum of two years after the employment relationship has ended.

If UBN is self-insured under the Sickness Benefits Act (ZW), the data necessary for self-insurance will be retained for a maximum of five years. If UBN is self-insured under the Return to Work Scheme for Partially Disabled Persons (WGA), the relevant data will be retained for the duration of the WGA process (i.e., for a maximum of ten years).

Business relationships

We process the following personal data from employees or representatives of our (potential) business partners (hereinafter: “partners”):

• (Business) Name and Address Information
• Phone number
• Email address
• Function

UBN processes the personal data of its business contacts for the purpose of maintaining a business relationship, establishing, maintaining, and fulfilling the agreement between UBN and the business contact, providing information, and complying with legal obligations imposed on UBN.

UBN processes the personal data of business contacts because this is necessary for the performance of the agreement, or because there is a legal obligation (e.g., tax obligations), or because it has a legitimate interest in doing so (e.g., providing information), or with your consent (requests for information via the contact form on the website). UBN may disclose the personal data of business contacts to others if this is necessary for the performance of its services (legitimate interest), including (prospective) employees, suppliers, audit bodies, government agencies, subcontractors, and companies and/or individuals it has engaged to perform certain tasks (including processors). In addition, UBN may disclose the personal data of its business contacts to others if UBN is required to do so under applicable laws and/or regulations, a court order or judgment, or after you have given your consent.

Privacy Policy

UBN implements various security measures to ensure that your personal data is protected. Personal data is accessible only to authorized personnel within UBN. Digital files can be accessed only using the personal login credentials of authorized personnel. UBN engages third parties and/or processors to provide services related to the management and security of its systems. UBN may provide personal data to these third parties. UBN authorizes these parties exclusively to use this data in connection with the services they provide. No data processing takes place outside the EEA. Should this change in the future, appropriate or suitable safeguards will be implemented.

Website visitors: Cookies

UBN may automatically collect and store certain information when you visit our website. For example, UBN may store your IP address and browser information each time you visit our site. UBN also collects information about visitor patterns and site usage. The information UBN receives from you is used to evaluate and improve the website, as well as for statistical purposes. UBN uses “cookies” on the website to gain a better understanding of how the website is used. This allows UBN to further improve the website’s content and navigation. A cookie is a very small text file that is placed on the visitor’s computer when they visit a website. This happens without the visitor noticing. The text file can be read during a subsequent visit, but only by the website that placed it on the user’s computer. The text file stores information about the user’s use of the UBN website. Cookies from the American company Google are placed via the UBN website as part of Google’s Analytics Service.

UBN uses Analytics to gather the necessary statistics on website usage. Google may disclose this information to third parties if required to do so by law, or to the extent that third parties process the information on Google’s behalf. UBN has no control over this. The information collected by Google is anonymized as much as possible. If you object to the use of cookies, you can disable them through your web browser settings. However, this may negatively affect the functioning of the UBN website on your browser.

Rights of data subjects

You have the right to access, correct, delete, restrict, object to, and transfer your personal data. In addition, you have the right to withdraw any consent you have previously given for the processing of your personal data.

To exercise the rights listed above, please send an email to fg@ubnuitzendbureau.com.

If you have any questions or complaints regarding UBN’s privacy policy, please contact us. You can do so by email at fg@ubnuitzendbureau.com. UBN will review your questions or complaints and respond within four weeks at the latest. If you are not satisfied with how your complaint is handled, you may file a complaint with the Dutch Data Protection Authority.