Adopted on 11 May 2021
Eumedion represents the interests of the members affiliated with it and is also an employer. Eumedion processes personal data for the performance of its activities. In this privacy statement Eumedion explains how it deals with personal data.
Which personal data does Eumedion process?
Eumedion processes personal data in order to be able to perform its activities. Eumedion processes personal data from representatives of members of Eumedion, from (former) employees of Eumedion, from (former) board members of Eumedion, from subscribers to the newsletter of Eumedion, from visitors of the annual symposium of Eumedion and from visitors of other activities organised by it, from contact persons employed at Dutch listed companies with whom Eumedion facilitates dialogues and from persons with whom the employees of Eumedion have contact in the normal course of the exercise of their function.
Eumedion processes the following categories of personal data:
- general data (such as first and last name, email addresses, physical addresses, company names);
- financial data (such as payment data);
- salary and employment data (such as contracts of employment); and
- identification data (such as photos and copies of ID cards).
For which purposes does Eumedion process personal data?
Eumedion processes personal data of the aforementioned categories of persons with the objective to:
- send the Eumedion newsletter to the persons who have subscribed to this
- send an invitation for the annual symposium of Eumedion or for other activities organised by it;
- be able to react to questions, suggestions, comments or complaints;
- execute the contract of employment with the employees of Eumedion;
- keep the information about Eumedion on its website up to date;
- comply with legal obligations to which Eumedion is subject; and
- represent the interests of the members affiliated with her, such as facilitating dialogues with Dutch listed companies, conducting research (or having research carried out) in the field of corporate governance and sustainability and consult policymakers and other stakeholders of Eumedion.
On what bases does Eumedion process personal data?
Eumedion only processes personal data if there is a basis for that in the General Data Protection Regulation. Eumedion uses the following bases:
- Consent by the data subject. Eumedion processes personal data of persons who are on the mailing list for the newsletter. Those data are only added to the mailing list if the data subject has given consent for this. Eumedion also processes photos of representatives of members and employees and personal data of visitors of the annual symposium of Eumedion and of visitors of other activities organized by it. Those data are only processed after consent by the data subject.
- Performance of a contract. Eumedion processes personal data of its employees in order to execute the contract of employment.
- Vital interests of Eumedion. Eumedion processes personal data from representatives of members of Eumedion (e.g. for sending invoices, keeping the information about Eumedion on its website up to date and conducting research (or having research carried out)), from (former) board members of Eumedion, from persons employed at Dutch listed companies with whom Eumedion facilitates dialogues and from persons with whom the employees have contact in the normal course of the exercise of their function. The processing of the aforementioned personal data is necessary in order to achieve the statutory objective of Eumedion.
- Compliance with legal obligations to which Eumedion is subject. Eumedion is legally obliged to transfer specific personal data of its (former) employees and its (former) board members to third parties, such as the tax authority, the Chamber of Commerce, the accountant and the pension fund to which the employees of Eumedion are affiliated.
Does Eumedion transfer personal data to third parties?
Yes. Eumedion only transfers personal data to third parties if it is legally obliged to do so (e.g. to the tax authority, the Chamber of Commerce, the accountant or the pension funds to which the employees of Eumedion are affiliated) or if it cooperates with a third party for the execution of its activities. Eumedion uses a third party for the execution of its activities in order to:
- send the newsletter of Eumedion;
- execute the payroll administration, the VAT declaration and the preparation of the annual accounts and other financial overviews; and
- provide IT services such as maintaining the online work environment, the facilitation of communication services and hosting of the website.
Eumedion thereby adheres to the requirements set by the General Data Protection Regulation. For example, Eumedion has concluded an agreement with the third parties used by it, in which agreements have been made to ensure the confidential and careful processing of personal data by those parties.
Eumedion does not make personal data available to third parties for commercial purposes. The third party that is used for sending the newsletter is located outside the EER. This means that in that regard Eumedion transfers personal data to a country outside the EER. This party offers (inter alia) appropriate safeguards by means of standard protection clauses adopted by the European Commission.
How does Eumedion process personal data?
Eumedion only processes personal data that are necessary for the performance of its activities and treats the personal data provided to it confidentially and carefully. Personal data are processed by Eumedion in accordance with the General Data Protection Regulation. The basic principle within Eumedion is that no more personal data are processed than necessary to achieve the objective for which they are collected. For example, Eumedion does not request more information from data subjects than necessary for the execution of its activities or for the offering of its services.
How does Eumedion protect personal data?
Eumedion implements appropriate organisational and technical measures to protect the personal data that Eumedion possesses against, among other things, loss, misuse and unauthorized access. These measures include that:
- all employees of Eumedion are obliged to treat personal data confidentially;
- a password policy or face recognition applies to the systems used by Eumedion;
- Eumedion’s office is only accessible with a key provided to employees;
- personal data are if necessary pseudonymised and provided with encryption; and
- back-ups are made (by a third party used by Eumedion) of the personal data in order to restore them in case of physical or technical incidents.
How long does Eumedion store personal data?
Eumedion does not store the personal data it processes longer than necessary for the objective for which they are provided or for the compliance with a legal obligation to which it is subject (e.g. fiscal legislation). Eumedion implements appropriate technical and organisational measures to protect the personal data stored by it. If the storage of personal data is no longer necessary, those data will be deleted.
What rights do persons whose personal data Eumedion processes have?
Persons whose personal data Eumedion processes, have:
- the right to withdrawn their previously given consent for the processing of personal data by Eumedion; for example every newsletter contains a link to unsubscribe. After deregistration the personal data will be deleted as soon as possible;
- the right to access, rectification and erasure of the personal data which Eumedion processes;
- the right to restriction of the processing of personal data by Eumedion;
- the right to object against the processing of personal data by Eumedion;
- the right to receive their personal data from Eumedion or to transmit them to another party;
- the right to lodge a complaint with Eumedion about the processing of personal data by Eumedion; and
- the right to lodge a complaint with the Dutch Data Protection Authority about the processing of personal data by Eumedion.
How can you contact Eumedion?
In case you have questions, comments or complaints about the processing of your personal data by Eumedion or about this privacy statement, please contact Eumedion:
Address: Stichting Eumedion
Zuid-Hollandlaan 7
2596 AL THE HAGUE
Phone: +31 (0)70 - 2040 300
E-mail: info@eumedion.nl
Is the privacy statement of Eumedion subject to amendments?
Eumedion reserves the right to amend this privacy statement. Therefore you are recommended to regularly check the privacy statement of Eumedion so that you are aware of eventual amendments. This privacy statement has been lastly adopted on 11 May 2021.
This is a translation of the Dutch Privacy Statement of Eumedion. The Dutch version will prevail whenever there is a divergent interpretation between the Dutch and the English version.