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Former BNG employees

Below, you will find an overview of the personal data that we may process, including the associated purposes and legal bases.

Request for a reference
Processing
References
Description/purposes
  • Providing information on former employees to potential employers, at the request of the data subject.
Categories of personal data
  • First and last name
  • Contact information
  • (Former) job title / role
  • Period during which the former employee was employed
  • Information about performance (if requested)
Special category personal data and criminal offence data
Not applicable
Basis
Consent of the data subject (Article 6 (1)(a) GDPR)
 
Pension
Processing
Pension administration
Description/purposes
  • Providing and managing data required for pension accrual and pension payments for pension administrators
 
Categories of personal data
  • Initials, Name
  • Address
  • Date of birth
  • Citizen service number (BSN)
  • Employment information
  • Salary information
Categories of personal data and criminal offence data
Not applicable
Basis
Legal obligation (Article 6 (1)(c) GDPR) – compliance with the Dutch Pensions Act (Pensioenwet)
 
Termination of employment terms and conditions
Processing
Termination of employment related insurance schemes
Description/purposes
  • Deregistering and administratively processing the termination of participation in employment-related insurance schemes (such as supplementary occupational disability insurance or life insurance) with the relevant insurers.
Categories of personal data
  • Initials, surname
  • Address
  • Date of birth
  • Employment and participation details
  • Policy details (if applicable)
 
Special category personal data and criminal offence data
Not applicable
Basis
  • Performance of the employment contract and the employment related benefit schemes forming part of it (Article 6(1)(b) GDPR) – the processing is necessary to terminate participation in employment related insurance schemes upon the end of employment and to complete the associated administrative obligations.
  • This processing follows directly from the arrangements that form part of the employment contract and the employment benefits package.
 
 
Absenteeism and WIA (Dutch Work and Income (Capacity for Work) Act) administration upon termination of employment
Processing
Sickness absence and WIA administration
Description/purposes
  • Providing personal data to the Dutch Employee Insurance Agency (UWV) and fulfilling administrative obligations under the Gatekeeper Improvement Act (Wet verbetering poortwachter) and the Dutch Work and Income (Capacity for Work) Act (Wet WIA) if an employee leaves employment while on sick leave.
Categories of personal data
  • Initials, surname
  • Address
  • Date of birth
  • Employment details
  • Sickness absence status (no diagnoses)
  • Reintegration steps (as far as legally permitted)
 
Special category personal data and criminal offence data
Health data is only processed at the abstract level permitted by law for employers; medical data are only processed by the company doctor. 
Basis
  • Legal obligation (Article 6 (1)(c) GDPR) – compliance with the WIA Act, the Gatekeeper Improvement Act and Structure of the Work and Income Implementation Organisation (SUWI) legislation.
  • For special data: Article 9 (2)(b) GDPR (labour law/social security).
 
Contacts with former employees
Processing
Contact with former employees
Description/purposes
  • Maintaining post-employment contact, for example for network initiatives, invitations to meetings or newsletters.
Categories of personal data
  • First and last name
  • Contact information
  • Former job title / role
  • Period during which the former employee was employed
  • Iformation relating to event registrations, such as dietary requirements
 
Special category personal data and criminal offence
  • Dietary requirements may indirectly reveal health aspects (for example, allergies) or religious beliefs (for example, halal, kosher).
 
Basis
Legitimate interest (Article 6 (1)(f) GDPR) – BNG’s interest in maintaining a network and community of former employees, e.g. for knowledge sharing, collaboration and strengthening relationships.