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1. What are personal data? 
The law defines personal data as all information relating to an identified or identifiable person. This means the combination of a name and date of birth, contact details, or a passport photo is deemed to be personal data. In addition, the law defines special personal data, which are particularly sensitive and need to be protected by additional measures. This includes health or financial data, for example.
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2. What data do we collect? 
At Wij zijn JONG, we collect a variety of personal data from children, potential customers (parents/guardians/carers), employees, trainees, applicants, suppliers, website visitors, professionals, volunteers, and third parties if necessary. 

We will record your data when you (the data subject) register for a service, when you conclude an agreement with us, or when you get in touch with us. See what data Wij zijn JONG collects here.

Where we collect personal data other than from a data subject, we will always know where the data come from. 

Security cameras and electronic access registration
Wij zijn JONG sometimes uses security cameras or using electronic access registration. This is to prevent crime, disturbances, and vandalism, and to protect people and their property. Signs are displayed indicating where security cameras and electronic access registration are used and who operates them. The cameras are positioned in such a way that they do not film at our childcare locations and capture as little as possible of the public highway or other property.

In the interest of children’s safety, a second adult should ideally be able to visually verify the integrity of the care facilities. Cameras are used in some cases, but these images will not be saved. [Back to top]

3. Why do we need to process personal data?
Wij zijn JONG processes personal data about children from 0 to 21 years old, customers (parents/representatives/carers), potential customers, employees, trainees, applicants, suppliers, website users, professionals, and volunteers so they can do their job properly. 

We process these data for the following reasons:
1. To provide adequate care, support, and counselling for children
2. To answer questions and respond to complaints from data subjects and, if applicable, third parties
3. As part of our commercial relationships
4. To comply with laws and regulations
5. To maintain our waiting list
6. For PR purposes/customer loyalty and communication about the organization’s developments
7. For financial administration
8. For business support
9. For logging information
If data are used for any other purposes, we will inform data subjects about this. [Back to top]

4. On what lawful bases do we process personal data?
We process these types of personal data because:

  • processing is necessary for the performance of a contract to which the data subject is party (e.g. a childcare contract, counselling, training agreement, or employment contract) or in order to take steps at the request of the data subject prior to entering into a contract; or
  • processing is necessary for compliance with a legal obligation incumbent upon us; or
  • the data subject has given their explicit consent to the processing of their personal data for one or more specific purposes mentioned in section 3 above. A data subject may withdraw their consent at any time.
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5. With whom do we share personal data?
Wij zijn JONG uses the personal data collected to conduct our own business. For this purpose, it may be necessary to share personal data with our own employees, trainees (where appropriate), and organizations that work for or with us, such as a financial service provider or a cloud/software vendor.

If another party or agency works for us (e.g. a professional counsellor or software provider), a data processing agreement is signed with that party, stating why they will receive and are allowed to process these data and how. Sometimes we need to share personal data on an ongoing basis with other referring or supporting agencies, such as a neighbourhood team, Veilig Thuis, Jeugdzorg, or the local health authority. In many of these cases, we sign a covenant which states the purpose for which personal data are shared and how they must be handled.

In addition, government agencies or competent bodies may request information from us that we are obliged to share, e.g. for accountability to the municipality or inspection by the local health authority, the Tax Administration, and the Education Executive Agency (Dienst Uitvoering Onderwijs, DUO). [Back to top]

6. How do we use and protect personal data?
Wij zijn JONG links personal data to unique codes (account number or staff number and/or complaint number) to facilitate communication. We do not process any personal data beyond what is necessary for our work. We never publish personal data about data subjects or other parties without their permission.

Anyone who has access to the personal data of data subjects is contractually bound by confidentiality.

Retention periods
We comply with the statutory retention periods. After the applicable period has elapsed, we destroy the personal data or store them in a way that they are no longer traceable to a person, for the purpose of statistical or trend research. Read more about retention periods here.

We take all necessary technical and organizational security measures to prevent misuse of and unauthorized access to personal data. Nevertheless, if there is a data breach, we will inform the data subjects affected as necessary.
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7. What rights do data subjects have?
Any data subject may exercise their right to be informed, right of access, right to rectification, right to erasure, right to restrict processing, right to data portability, and right to object to processing of their data, free of charge. A request to exercise these rights will be answered within four weeks. If we cannot process the request within this period, we will inform the applicant within four weeks of the reason for the delay and the latest date of reply.

Requests and/or questions may be submitted to the Data Protection Officer (DPO) by email or in writing. When a request to be informed is made, the applicant will be given a complete list of the data processed about them, the source of the data, the recipients of the data, and the purposes for processing the data*. 

The following data are not provided by us: 
o Personal work documents and notes for internal use
o Third-party personal data, e.g. a complaint about a child submitted by the parents of another child
o Personal data used for the prevention, detection, and prosecution of criminal offences and other cases referred to in Article 10 of the GDPR. 

Before a request to be informed or to object is dealt with, the data subject must provide personal identification in the form of an original ID card or passport. If the data subject is under 16 years of age or has no legal capacity, the request must be submitted by their legal guardian.

Requests for rectification
Requests to rectify personal data are only accepted if the data are incorrect, incomplete for the purpose for which they were collected, or if the data are not relevant or are processed unlawfully. If the rectification request is accepted, Wij zijn JONG will implement the changes as soon as possible. We will also report any changes to third parties with whom such data have been shared in the past, unless this is not possible or requires a disproportionate cost or effort. We will then erase the data as soon as possible.

Requests for erasure
Data will be erased if, for example, it is determined that the personal data are no longer necessary for the purposes for which they were collected or otherwise processed, or if the data subject withdraws their consent and there is no other basis for processing. We also erase personal data if the data subject has raised a legitimate objection to the processing, if the personal data have been processed unlawfully, to comply with a legal obligation incumbent upon us, or if personal data have been collected in connection with a direct offer of online services to a child. 

Requests to be forgotten
In certain circumstances, data subjects have a right to be forgotten. This right is in line with the right to data erasure. This could be appropriate for situations in which Wij zijn JONG has published the data subject’s personal data (e.g. online) and the data subject would like the data to be deleted. In addition to deleting the data from our own systems, we take reasonable technical and organizational measures to inform other data controllers who process the personal data that the data subject would like to be forgotten. This means that any link to, copy of, or reproduction of the data must also be erased. The right to erasure and the right to be forgotten can be exercised by anyone, but particularly in relation to the processing of children’s data. Even if a data subject who gave their consent to processing as a child is now an adult, we give serious consideration to this, as the data subject might not have been fully aware of the risks of processing at the time.

Requests to restrict processing
Sometimes, the data subject may require personal data processing to be suspended. For example, it might be necessary to restrict processing while the personal data are checked for accuracy, or in the event that Wij zijn JONG no longer needs to process the personal data for the original purposes, but the data subject needs this data to bring about, exercise, or substantiate a legal claim. Before we lift the restriction, the data subject will be informed so that a complaint can be lodged with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) or a legal claim can be brought in good time.

Right to data portability
The right to data portability applies only to data that are processed automatically by us on the basis of the following principles: ‘the unambiguous or explicit consent of the data subject’ or ‘a necessity for the performance of the agreement’. We are committed to developing data formats that make it easier to port the data and therefore implement the right to portability.

Right to object
A data subject may invoke their right to object in one of three situations:
o 1. Because of a personal objection to processing on the basis of the principle that “processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority” or a legitimate interest of Wij zijn JONG. We will then stop processing, unless there are compelling, legitimate grounds which override the interests, rights, and freedoms of the data subject.
o 2. The data subject may object to the processing of their personal data for direct marketing purposes. We always respond to a request to object.
o 3. The data subject may object to the processing of their data for scientific or historical research or for statistical purposes on the basis of specific reasons relating to their situation. We will comply with a request to object unless processing is necessary for the performance of a task carried out in the public interest.
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8. Right to lodge a complaint or bring legal action
You as a data subject have the right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) if you believe that Wij zijn JONG is not complying with the General Personal Data Regulation. Please visit https://autoriteitpersoonsgegevens.nl/en

You can also bring legal action before a court on the basis of an unlawful act. However, we will always try to fulfil our obligations before it comes to that.
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9. Personal data and digital media
When visiting and using our websites, we request your consent to process your personal data. If someone fills in a contact form on one of our websites or sends us an email, the data will be kept as long as is necessary for us to respond and process the query in full. We process the personal data we receive from these websites in accordance with this Privacy Policy.
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Read more about our Cookie Policy.

*Parents/carers have the right to access the personal data we process in relation to the child in their care. In the case of divorced parents, both parents are entitled to receive the same information about their child. Parents without any custody of their child do not have the right to access that child’s personal data, but do have the right to receive key information. Before Wij zijn JONG provides any information, parents without any custody of their child should ask the parent with custody for their consent to receive that information. If the parent with custody does not give their consent to information being provided, Wij zijn JONG will balance the interests of the child and those of the parent without custody.

Our Data Protection Officer (DPO) monitors how we implement and comply with the General Data Protection Regulation (AVG) within the organization.