The Privacy Regulations are a company-wide document that governs how FritsJurgens deals with GDPR-qualifying personal data. It is one of the policies governed by the Operations circle.

Privacyreglement

This policy is based on the General Data Protection Regulation (GDPR: link), which took effect on 25-05-2018.

The Privacy Policy for the Protection of Personal Privacy in the Context of Personal Registration was held for services provided by FritsJurgens.

Responsible publisher: FritsJurgens © 05-12-2023. All rights reserved. No part of this publication may be reproduced, stored in an automated database, or disclosed in any form or manner without prior written consent from the responsible publisher.

In this policy, the following terms are defined:

Term	Nederlandse term	Definition
Privacy	privacy	The right of individuals to protect personal privacy concerning recording and providing personal data.
FritsJurgens	FritsJurgens	Each of the companies under the FritsJurgens holding.
Data Subject	betrokkene	The individual whose data is processed. This includes employees, network contacts, customers, debtors, and suppliers.
Data Controller	verwerkingsverantwoordelijke	The entity determining the purpose of processing personal data; within FritsJurgens, this is the management.
Processor	verwerker	The entity authorized to process personal data; within FritsJurgens, this includes the administration and employees, including hired external subcontractors.
Processor Supervisor	bewerker	The entity processing personal data under the authority of the data controller.
Recipient	ontvanger	Someone who receives personal data.
Personal Data	persoonsgegevens	All information that can be traced back to an identified natural person.
Health Data	health data	Personal data related to a person's physical or mental health, including healthcare data provided.
Processing of Personal Data	verwerking van persoonsgegevens	Any action involving personal data, including but not limited to collecting, recording, organizing, storing, updating, modifying, retrieving, consulting, using, disseminating, or destroying data.
Consent	toestemming	Demonstrable agreement of the data subject to the intended data processing, provided through signature, checkbox + signature on a consent form, data submission by the data subject who has previously consented to recorded data, or written consent such as email or WhatsApp message.
Confidentiality	geheimhouding	Every employee of FritsJurgens who has access to the personal data of employees and customers is obliged to maintain confidentiality. This obligation also applies after termination of employment.

Throughout the policy, for some words, the Dutch translation is given in italics, to clarify.

1. This policy applies to all paper files, all digital files, and unwritten information within FritsJurgens, as well as its associated data exchange and processing.
2. FritsJurgens processes information in the following categories
   • For salary: Name, Address, Postal Code, Citizen Service Number, contact details such as position/salary scale/salary, a copy of ID, and the signed tax declaration.
   • In case of sick leave: name, address, postal code, citizen service number, salary, nature of sick leave, and status of the reintegration progress.
   • For internal communication: Name, function/position, business email address, business phone number, schedule, and tasks.
   • For company outings: Dietary preferences and allergies.
   • For emergencies: Emergency contact information.
   • Regarding employment, we share data with:
     • Payroll administration salarisadministratie (Mulderij & Partners): for payroll administration. They use the online payroll administration package Loket.nl. The payroll administration also provides the legally required information to the Tax Authorities.
     • Pension Fund pensioenfonds (ASR): exclusively for the initial registration with them (you subsequently permit them to process and transmit your data to the payroll administration; they are the data processor for this).
     • Possible Sick Leave Insurance ziekteverzuimverzekering (currently not applicable): This includes personal data such as Name, Address, Citizen Service Number BSN, Salary, and sick leave percentage.
     • Occupational Health Service arbodienst (Alpina@Work): The occupational health service has insight into the nature of sick leave.
     • Possible Absence Guidance verzuimbegeleiding (Alpina@Work): Communication with the absence guidance organization involves reintegration in case of prolonged illness.
     • Accountant (Afier): The accountant has access to and receives a copy of the entire administration, including the payroll administration.
   • For work-related activities, we share data with:
     • IT partner (MatenICT), software suppliers (Microsoft, Zoho, Holaspirit): your name and business contact details.
     • Colleagues i.e. all employees and interns within FritsJurgens. Through the administration package, all employees have access to all colleagues' work schedules and business contact details. This includes name, position, business email address, business phone number, work schedule, and roles.
     • Organizer of company outings: name, dietary preferences, and allergies (if participating).
     • Subcontractors and FritsJurgens seconded employees: considered external colleagues. The administration ensures that these external colleagues have access to the business contact details of the employees they are dealing with.
     • Customers: only name, position functietitel, business email address, and work schedule.
     • Website: the name and function/position of the employee.
     • Emergency contact: This involves the contact details of one or more individuals who should be contacted in emergencies and with whom only the nature of the emergency is shared.
   • Regarding data of potential customers and network contacts, we register:
     • Name, business contact details, inquiry, and role within the company we have contact with.
     • All communication (emails, chats, phone notes).
     • All other information these customers offer, including search behavior on our website and media expressions.
     • Company data, including what we can find through data enrichment from publicly accessible internet sources.

This policy applies within FritsJurgens and relates to the processing of personal data of:

• Employees, including interns.
• (Potential) customers and network contacts, such as the relationship with and data of other individuals in the personal network.
• Debtors, such as clients and budget managers.
• Suppliers, including subcontractors and other companies.

1. The purpose of collecting and processing personal data is to have the necessary information for conducting market analysis, sending newsletters (if subscribed), and managing personnel and the company's functioning.
2. The data of employees are collected and processed for:
   1. Making and executing an employment or internship agreement.
   2. Conducting payroll administration.
   3. Collaborating as colleagues.
   4. Being prepared for emergencies.
3. The data of (potential) customers and network contacts are collected and processed for:
   • 
   1. Communicating in emergencies.
   2. Coordinating services with the individual's network.
4. The data of debtors (i.e. customers), are collected and processed for:
   1. Executing and communicating about provided orders.
   2. Invoicing and receiving payment.
   3. Discussing potential new orders.
5. The data of creditors (i.e. suppliers and subcontractors), are collected and processed for:
   1. Executing and communicating about provided orders.
   2. Paying invoices and accounting for payments.
   3. Discussing deliveries or services.

1. The management is responsible for ensuring the proper processing and management of personal data and can be held liable for it, except in case of force majeure.

• When the data subject has given written consent for the processing of their data, the management must be able to prove that this has occurred.
• The data subject has the right to withdraw their consent at any time.
• The data subject has the right to data porting.
• The data subject has the right to be forgotten.
• The data subject has the right to access.
• The data subject has the right to rectification and supplementation.

Different documents have different retention periods:

Destroying paper files
Destroying digital files
Destroying access logbook	5 years after mutation date.
Destroying email archive
Destroying digital calendars	5 years after the end of the fiscal year.
Destroying personnel file	2 years after termination of employment.
Destroying payroll administration	7 years after the end of the fiscal year.
Destroying financial information (debtors)	7 years after the end of the fiscal year.
Destroying list of destroyed files	20 years after destruction.
Destroying digital backups	5 years after backup date.
Destroying after approved destruction request	3 months after the request.
Destroying job application letter and CV	4 weeks after completion of the job application process, or one year for open applications.

The data subject can file a complaint with the management about data processing. This can be done in writing via info@fritsjurgens.com.

• Any future changes of this policy will be approved by the management and presented in a meeting for all employees.
• Changes become effective no sooner than four weeks after having been announced to all involved.
• This policy becomes effective per 01-01-2024
• The policy is available on this wiki page or in print through the reception of FritsJurgens.

• These privacy regulations are referred to from: De toestemmingsverklaring personeel
• A similar regulation is found on The website
• Various wiki pages