version: september 2024
UBN Uitzendbureau BV and UBN Flex BV (hereinafter: 'UBN' and also 'we' and 'us'), having its registered office and principal place of business in (3721 BA) Bilthoven at Leyenseweg 1, registered in the trade register of the Chamber of Commerce under number 30148921, has various clients to which it supplies its employees. UBN also provides services in the area of recruitment and selection. For our services, it is necessary that we process your personal data. We value your privacy and we therefore comply with the rules arising from the laws and regulations in the field of privacy. By means of this privacy statement we want to make clear to you 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 and employees, trainees and other persons employed by UBN (including self-employed persons) who are made available to clients through UBN;
- (internal) employees of UBN who are not made available to clients;
- all visitors to our website;
- employees or representatives of our (potential) business associates (including suppliers and clients of UBN).
Purposes and bases of processing personal data of (prospective) employees
Personal data are processed by UBN for the following purposes:
- Assessing your suitability and availability for employment placement;
- Your mediation into employment;
- The establishment of an employment relationship and the administration relevant to it;
- Maintaining labor relations and personnel and payroll records;
- The execution of the employment contract between you and UBN;
- Entering into and executing the agreement between UBN and our clients;
- Informing you about our services;
- Quality and management purposes, such as audits, auditing and certifications;
- Promoting your personal development, through training, for example;
- Meeting our reintegration obligations;
- Applying for grants, premium discounts, etc.;
- Compliance with legal obligations imposed on UBN;
- Answering your questions;
- Complying with a court order or judgment.
Personal data are processed only if one of the legal bases is met.
- Most processing of personal data is done because it is necessary for the performance of a contract in which you are involved.
- Personal data are also processed to comply with a legal obligation incumbent on UBN, such as providing personal data to the tax authorities under the Payroll Tax Act or processing personal data under the Gatekeeper Improvement Act.
- In some cases, the processing is necessary to satisfy the legitimate interests of UBN or a third party, except when the interests or fundamental rights and freedoms of you outweigh the interests of UBN and/or the third party.
- When (prospective) employees upload their own passport photo through My UBN, the passport photo is processed.
- Questions asked via web forms or surveys.
Registration with UBN and placement into employment
When you register, please provide us with the following personal information:
- NAW data
- Phone number
- Email address
- Date of birth
- What education(s)/work experience(s)/certifications you possess
- Whether you possess a driver's license (if and to the extent relevant to the position)
- Availability and desired salary
- Gender
- Copy of proof of identity (and therefore also the data on it, such as BSN, passport photo and nationality)
- Copy of residence permit or work permit (if applicable)
- Bank account number
Should you choose to provide us with your curriculum vitae (hereafter, "resume") when registering, please include the following information: name (initials, given names, surname, call sign), address, telephone number, email address, desired professions/functions, work experience, education, courses and competencies. We discourage you from including any information other than these in your resume.
If special requirements are set for a particular job in terms of medical suitability, UBN may in certain situations obtain information about your medical suitability for the job by means of a medical examination. The result of that examination (and not the medical data itself) will be provided to UBN by the company doctor only after you have given your consent.
If a Certificate of Good Behavior (VOG) is necessary for the (desired) position, UBN is permitted to record in the records that a VOG has been issued. Should a VOG not be issued, UBN will not record anything about it in the records.
You do not have to provide information about your health to UBN if it is not directly relevant to the performance of the job for which you are applying. However, you are required to report health conditions that you know or should understand would make you unsuitable for the position.
Provision of personal data to client
If compatible with the purpose for which you provided UBN with your personal data, UBN is allowed to provide your personal data to potential clients. UBN will provide no more information than necessary for the purposes for which you have provided UBN with your personal data. This concerns the following personal data: name, place of residence, date of birth, e-mail address, telephone number, education, work experience (if and insofar as relevant to the position), courses (if and insofar as relevant to the position), other data relating to your work experience (if and insofar as relevant to the position).
If and to the extent relevant to the position, UBN may also provide the following information to potential clients: whether you have a driver's license, whether a Certificate of Good Behavior (VOG) has been issued to you. If no VOG has been issued, we will not make any statements about this to the potential client. If a medical examination is required: whether you are suitable for the position (based on the medical examination).
The moment you start working for a client of UBN, UBN may also provide your BSN and number of your ID, and if applicable, a copy of your residence permit, to the client.
ZZP'ers
For freelancers, UBN also processes the following data: bank account number, Chamber of Commerce registration number, excerpt from the Chamber of Commerce trade register, copy of third-party liability insurance (relating to the company's liability), VAT number. No copy of identity card or BSN will be provided. However, if the self-employed person comes from a non-EEA country (all EU countries plus Liechtenstein, Norway and Iceland), a copy of proof of identity is processed. Finally, a copy of 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. These include complaints, warnings, personal work notes from the supervisor, vacation entitlements and correspondence about performance. UBN is permitted (whether required or not) to process certain personal data of yours, for the purpose of payroll administration. These include pay slips, wage garnishments, pension information, annual statements and a payroll tax statement. In case of a sick report, UBN may process a number of your personal data, such as: the (nursing) address, the probable duration of your absence, current appointments and activities and whether you fall under one of the safety net provisions of the Sickness Benefits Act (but not under which safety net provision). After the company doctor has been consulted, among other things, it is processed which work you are no longer or still able to perform and any advice on adjustments, work facilities or interventions to be made by UBN for reintegration.
Situations may arise that make the provision of certain personal data about you necessary for the protection of UBN's or the client's legitimate interests. This may be the case, for example, if specific reintegration activities must take place in connection with your reintegration.
Providing personal data to others than clients
UBN may disclose your personal data to others if compatible with the stated purposes and bases, including suppliers, audit bodies, government agencies and companies and/or persons UBN has engaged to perform certain tasks (including processors).
Retention periods
Your personal data will be kept as long as this is necessary for the realization of the purposes. After the (legal) retention period, your personal data will be destroyed. If you have not worked for UBN, UBN will in any case not retain your personal data for longer than two years. If a copy of your proof of identity was made at the time of your registration, UBN will retain this copy until it is no longer necessary. In any event, UBN destroys the copy no later than four weeks after the copy is entered in UBN's records, unless you have entered into an employment contract with UBN during that four-week period. At the time you notify UBN that you no longer wish to be mediated into employment, UBN will delete all your personal data from its system at that time. If an employment contract (or other type of relationship) has been concluded between you and UBN and has ended, UBN will not retain your personal data for longer than two years, unless UBN has a legal obligation to retain the personal data longer. A longer (legal) retention obligation applies to UBN (in any case) in the following situations:
- Personal data relating to your health may be kept longer than two years if there is an employment conflict or a dispute over the award of disability benefits. The relevant data will be deleted when the conflict/dispute has ended.
- For all personal data contained in payroll records, UBN retains them for seven years.
- Form loonheffingen that you filled out (at least the document in which you indicated that UBN should or should not take the payroll tax credit into account), copy of ID, name with initials, date of birth, Citizen's Service Number, address with zip code, place of residence, and in case you do not live in the Netherlands, the country of residence and the region of residence are kept for five years.
If a reintegration file was built up during your employment - in case of long-term illness - and it was closed again during your employment, UBN will in principle retain this reintegration file for no longer than two years (after completion of the reintegration). Administrative data about your sick leave (such as data for the continued payment of wages, date of the sick report, duration of the absence and the date of recovery) are in principle kept for a maximum of two years after the employment relationship has ended.
If UBN is self-insurer for the Sickness Benefits Act (ZW), the data necessary for self-insurance will be retained for a maximum of five years. If UBN is self-insurer for the Work Resumption of Partially Disabled Workers (WGA) scheme, the relevant data will be retained for the duration of the WGA trajectory (i.e. a maximum of ten years).
Business relationships
We process the following personal data from employees or representatives of our (potential) business associates (hereinafter "associates"):
- (Business) contact information.
- Phone number
- Email address
- Function
Personal data of relations are processed by UBN for maintaining a business relationship, establishing, maintaining and performing the agreement between UBN and the relation, providing information, complying with legal obligations incumbent on UBN.
UBN processes the personal data of business relations, 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 to do so (e.g., providing information) or with your consent (requesting information through the contact form on the website). UBN may pass on the personal data of relations to others if this is in the interest of providing its services (legitimate interest), including (prospective) employees, suppliers, audit bodies, government agencies, subcontractors and to companies and/or persons it has engaged to perform certain tasks (including processors). In addition, UBN may transfer the personal data of relations to others if UBN is required to do so under applicable laws and/or regulations, court order or judgment or after you have given your consent.
Personal data protection
UBN takes various security measures to ensure that your personal data is protected. Personal data can be accessed only by authorized personnel within UBN. Digital files are accessible only through 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 only authorizes these parties 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 met.
Visitors website: Cookies
UBN may automatically collect and store certain information when you visit our site. For example, UBN may store your IP address, browser information each time you visit our site. UBN also collects information about visit patterns and site usage. The information UBN receives from you is used to evaluate, improve and for statistical purposes. UBN uses 'cookies' on the website to gain more insight into the use of the website. This allows UBN to further improve the offer and navigation of the website. A cookie is a very small text file that is placed on the visitor's computer when visiting a website. This happens without the visitor being aware of it. The text file can be read on a later visit, but only by the website that gave it to the user's computer. The text file stores information about the user's use of UBN's website. Through UBN's website, cookies are placed by the American company Google, as part of Google 's Analytics Service. UBN uses Analytics for the necessary statistics about the use of the website. Google may provide the information to third parties if Google is legally required to do so, or to the extent that third parties process the information on Google's behalf. UBN has no influence on this. The information Google collects is anonymized as much as possible. If you object to the use of cookies, you can disable these cookies via the settings of your internet browser. However, this may negatively affect the functioning of UBN's website on your browser.
Rights of data subjects
You have the right to inspection, correction, deletion, restriction, opposition and transfer. In addition, you have the right to withdraw consent once given for processing your personal data. To exercise the above mentioned rights, please send an e-mail to fg@ubnuitzendbureau.com.
If you have any questions or complaints regarding UBN's privacy policy, please contact us. This can be done by e-mail at fg@ubnuitzendbureau.com. UBN will consider your questions or complaints and respond within four weeks. If you are not satisfied or the handling of your complaint, you can file a complaint with the Personal Data Authority.