Privacy Statement

Privacy Statement of the Trimbos Institute

The Trimbos Institute highly values your privacy. This Privacy Statement details how the Trimbos Institute handles personal information of people who are not employed by the Trimbos Institute, the rights you have, and whom to contact for more information.

The Trimbos Institute does scientific research, provides information, and offers several services and products with the purpose to improve mental health.

This is about the processing of personal data with the purpose of doing research; developing and offering interventions, tests, guidelines, preventative measures, and information in that context; offering information and advice to the public via the websites www.alcoholinfo.nl, www.drugsinfo.nl, www.rokeninfo.nl, www.gameninfo.nl, and www.ikstopnu.nl (hereafter to be referred to as the Info-Lines) by way of telephone, chat and email; the web shop; trainings and e-learnings; conferences; newsletters (hereafter jointly referred to as Service).

We process, store, and secure these personal data with the utmost care in accordance with the General Data Protection Regulation (GDPR) ( Algemene Verordening Gegevensbescherming, AVG).

Contents

1. Contact data of the Trimbos Institute and the Data Protection Officer
2. Principles and Codes of Conduct
3. How does the Trimbos Institute collect personal data?
4. Which personal data does the Trimbos Institute process and for what ?
5. Legal grounds for processing
6. Does the Trimbos Institute collect data about children younger than 16 years old?
7. How long will the Trimbos Institute keep your personal data?
8. Who does the Trimbos Institute share your personal data with?
9. How does the Trimbos Institute protect your personal data?
10. What are your rights?
11. Complaints?
12. Changes
13. Links

1. Contact data of the Trimbos Institute and the Data Protection Officer

The Trimbos Institute

Address: Da Costakade 45, 3521 VS Utrecht
Email: info@trimbos.nl
Telephone: (31)(0)30-2971100

Data Protection Officer

Email: fg@trimbos.nl

2. Principles and Codes of Conduct

The Trimbos Institute only collects personal data that is necessary for the purposes for which these are being collected and processes your personal data only for those specific purposes.

When personal data are no longer needed for the purposes for which these were collected, the collected data will be destroyed or anonymously processed, for instance for quality or research purposes. The remaining data cannot be traced back to identifiable people; they remain anonymous. In that case it can no longer be considered processing of personal data.

We work in accordance with the following codes of conduct, among others:

  • The Netherlands Code of Conduct for Scientific Practice (the leading principle for integrity policy)
  • The Code of Conduct for the Use of Data in Health Research
  • The Code of Ethics for Psychologists

If needed, research protocols are subjected to a Medical Ethical Committee in order for us to also meet the requirements of the Medical Research Involving Human Subjects Act.

3. How does the Trimbos Institute collect personal data?

We collect your personal data in a variety of ways, for instance:

  •  when you provide us with these data in order to make use of our Services, for instance via a website, app, or questionnaire of the Trimbos Institute;
  • when you call us (or leave a message to call you back), email us, or contact us via this or another website of the Trimbos Institute;
  • when you visit us;
  • via third parties with whom we cooperate in the context of our research or Services.

4. Which personal data does the Trimbos Institute process and for what?

In the context of providing our Service we can process the following personal data.

Contact details

Whenever you participate in research, place an order via the web shop, take an (accredited) training, request information from us or ask to send you a newsletter, or make use of other Services we provide or provide services to us, we will process contact information – depending on what is needed for this Service – such as: name, address, postal code, city, telephone number, email address, gender, age, function, name organization and/or (BIG)registration number.

These contact details are being used:

  • for communication in the context of (follow-up)research;
  • for communication in the context of other Services we provide and in order to enable such Services;
  • in order to let you know whether such Service is appropriate for you or not;
  • for processing your requests or complaint;
  • for providing and exchanging information about (the Services of) the Trimbos Institute;
  • for making offers to already existing clients for the same or similar products or Services;
  • for administrative purposes;
  • for communication in the context of contracts with suppliers and in order to enable performing such contracts with them;
  • for communication in the context of job application procedures;
  • in order to meet legal requirements and in order to exercise or defend our rights;
  • for security purposes such as entrance control to our premises as well as providing you with login details for participating certain Services or research;
  • in order to invite you by email/text message provide us with your opinion about the Services after having performed such Services;
  • in order to personally inform you after filling in questionnaires.

Special Categories of personal data

We consider Special personal data to be data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, data concerning health or mental condition of participants and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning a natural person's sex life or sexual orientation, and data of a criminal nature.

Due to the nature of our Services we process special categories of personal data in the context, for instance, of research, interventions, and the Info-Lines. This pertains particularly to data relating to health or mental health of the participants. We process the data you provide us in that context based on your explicit consent. You can withdraw your consent at any time. Under the heading ‘What are my rights’ you can read how you can do so.

Research Data

When you participate in research we process personal data that are needed for answering the research question or questions, such as name, address, postal code, city, gender, date of birth, function, country of birth; special categories of personal data (such as data about health or mental health of the participants); user data of websites and apps that are being used in the context of the research.

Which data are being processed in a specific research study is stated in an information letter or privacy statement pertaining to that research and/or from the information displayed at the particular website or app.

The following Research Data are being used:

  • in order to evaluate whether you qualify for the research based on your consent;
  • for the research purposes as further detailed in the information letter or the appropriate privacy statement on the website or app you receive or are able to check before you decide to participate in the research based on your consent.

Payment Information

When you make use of one of our paid Services or when you are entitled to a payment from us, we will process personal data – depending on what is required in the specific case – among which name, surname, address, postal code, city, date of birth, bank account or credit card number, VAT number, date of birth, and fiscal number (Dutch BSN number, only when necessary for fiscal purposes).

This Payment Information will be used for:

  •  processing your payment if you make use of our Services and/or products or if we make use of your services;
  • paying or providing whichever allowance you are entitled to for participating in a particular research;
  • being able to exercise or defend our rights;
  • complying with legal obligations.

Chat Information via the Info-Lines

If you make use of the opportunity to chat with us via one of the Info-Lines, it may be that we process the following personal data: name, email address, age, gender, the chat information itself. You can make use of these functions on the basis of anonymity. You yourself choose which information you want to share and therefore which (special) personal data will be processed.

The Trimbos Institute anonymizes all chats bi-monthly by removing all identifiable personal data.

These Chat data are being used to provide information and advice when requested, and in order to be able to report statistical data on an anonymous basis, and in order to improve these Services.

Traffic Data

When you make use of a website, an app, or a Service provided on those, we can process personal data such as the date of signing up, the duration you were logged in, surfing behavior within the website or app, IP-address, other unique device identifiers and/or the (special) personal data registered in the app or website.

These traffic data of websites and apps are being used for:

  • technical user purposes, such as sufficient server capacity for the number of visitors;
  • providing the Service;
  • determining the effectiveness of the Service;
  • statistical analyses of visiting and clicking behavior, and optimizing the website, app and/or Service.

See also our cookie statement.

Login and account data of websites and apps

When you make an account in a website or app we process the following personal data: user name, email address, password, and date of birth.

  • The login and account data are being used for age checkup, authentication, and admission to and control of your account and these are a security measure;

Data of job applicants, volunteers, and independent contractors

When you apply for a job with us we process contact details and other data you include in your résumé as well as other data that may be/that are of importance in the context of assessing suitability of the candidate, for instance references and attestations.

These data are used to communicate with you about your application, to assess whether a candidate is suitable for the particular vacancy, as well as for preparing and entering into an agreement.

Camera images Trimbos Institute terrain

There are cameras at our terrain which record images of our entrance and of our parking areas at the address Da Costakade 45 in Utrecht.

These data serve to secure and protect objects in and around our building and to protect the safety and health of each one visiting our building and also to record incidents.

Cookies

See our Cookie Statement.

5. Legal grounds for processing

We process your personal data because we need these data for entering into or executing an agreement with you, because we have a legal obligation, because we have a legitimate interest in doing so, or because you gave (explicit) consent.

If you give the Trimbos Institute consent to process your (special) personal data for specific purposes, you can withdraw your consent at any moment. Under the heading ‘What are my rights’ you can read how you can do so.

Would you like more information about the legal grounds for processing? Please contact us via info@trimbos.nl

6. Does the Trimbos Institute collect data about children younger than 16 years old?

Within the context of our Service geared towards young people, it is possible we collect personal data of children younger than 16 years old, for instance in the context of research among young people. In those cases we do not process the data without prior consent of the legal representative(s).

Regarding the Info-Lines providing information, help, and advice to young people previous consent by the legal representative(s) is not required. The users themselves decide which information will be shared and therefore, which (special) personal data will be processed.

Other than that, the Trimbos Institute does not collect personal data of children younger than 16 years old. Therefore we kindly request that you inform us when you know that somebody younger than 16 years old has provided their personal data to us via one of our websites or apps without prior consent of the legal representative(s). In that case we will take the measures that reasonably are required to as soon as possible erase all personal data provided by that person.

You can contact us via info@trimbos.nl.

7. How long will the Trimbos Institute keep your personal data?

The Trimbos Institute will not keep your personal data any longer than necessary.

The Trimbos Institute set a policy on retention periods with terms and/or criteria with which is determined how long specific data are being kept. After that, the personal data are erased or anonymized.

In general, the Trimbos Institute maintains the following principles.

If the research does not fall under the scope of the WMO, the Research Data are being kept for ten years after finalizing the research or longer when such personal data are still of scientific interest. The contact details and the consent statement are being kept for five years after finalizing the research.

In case of research falling under WMO, the research data are being kept for fifteen years after finalizing the research or longer when such data are still of scientific interest. The contact details and the consent statement are being kept for fifteen years after finalizing the research.

Data of job applicants are being kept up to four weeks after finalizing the application procedure or, with consent of the applicant involved, up to one year after finalizing the application procedure.

The personal data processed via the Info-Lines are kept no longer than is necessary for answering the question, and the chat data are anonymized every two months.

The camera images are being kept for a maximum of four weeks, unless there is a valid reason to keep the images longer in order to deal with incidents that were noted.

Information that is needed in order to determine the obligations and financial position of the Trimbos Institute are being kept for seven years.

If required for finalizing a legal obligation or legal procedure the personal data needed for such may be kept longer.

Do you have any specific questions about this? Contact us via info@trimbos.nl

8. Who does the Trimbos Institute share your personal data with?

In principle the Trimbos Institute does not share your personal data with any third parties, except:

  •  when it involves third parties who perform a duty for us within the context of our Services, such as IT service providers and parties handling the (financial and practical) aspects of purchases and parties participating in or cooperating with any research;
  • when in accordance with applicable laws and regulations we are obligated to provide certain data or when such is permitted;
  • when we are of the opinion that providing personal data to other institutions or organizations is necessary in order to protect (vital) interests of a person or when this is necessary or desirable to enforce the law in the context of fraud prevention or investigation, and also when it is necessary to exercise or defend our rights;
  • when it is necessary for obtaining advice or support from our professional consultants.

When we provide data to a third party we make agreements with this party such as (i) that they cannot use these personal data for any other purposes than those for which the personal data are being provided and (ii) that they take security measures needed for protecting the personal data.

In principle, the Trimbos Institute processes the personal data within the European Economic Area (EEA). In case the data are provided to countries outside the EEA, for instance in the context of international research, we inform parties involved about this as well as about the existence of an adequacy decision of the European Commission, or if this is not the case, what the appropriate or right safeguards are, how a copy of these can be obtained, or where they can be consulted.

9. How does the Trimbos Institute protect your personal data?

The Trimbos Institute takes appropriate technical and organizational security measures required to protect your personal data against loss, misuse, and unauthorized access by others.

We optimize security, for instance by:

  • saving data separately and using encryption, where appropriate;
  • using password protection;
  • limiting access to your personal data (only those people needing access for purposes outlined above will get access);
  • contractual provisions to confidentiality.

We invite you to help us in protecting your data when you make an account via one of the websites or apps. You can do so, for instance, by using an up-to-date virus scanner and by never sharing your password with others.

The Trimbos Institute implements an active policy with respect to the detection and following up of any potential data leaks and security incidents. Part of the information security policy is a protocol to ensure timely follow up to signals of possible data leaks and security incidents.

10. What are your rights?

The right to withdrawal of consent

If we process your personal data based on your consent, you are at all times entitled to withdraw your consent. This does not affect the lawfulness of processing based on consent before the withdrawal.

Right to access

You are entitled to ask the Trimbos Institute which personal data  concerning yourself we process. You can make a request to access these personal data and ask the Trimbos Institute for a copy thereof.

Correction

You can request the Trimbos Institute to correct your data. For instance, do you wish to receive mail or any other (digital) correspondence from the Trimbos Institute at a different address, then you can request to correct these data. Has your last name changed? You can also request to adapt your data.

You also can request the Trimbos Institute to adjust your data should these appear to be incorrect or incomplete. The Trimbos Institute will promptly adjust your data.

If you have your own account (for instance via the web shop or via an app), you have access to a large part of the personal data registered about you. You can at any time change or erase a number of data, such as making changes to your account data.

Other rights

You also have the right:

  • to object to processing of your personal data which is  based on our legitimate interest (in case of direct marketing this can be done for free and without stating any reasons) or – in specific cases – the right to restrict processing your personal data;
  • in specific cases: to have your personal data be erased (the ‘Right to be Forgotten’), for instance when you withdraw your consent to process your personal data;
  • to obtain your personal data in a structured, commonly used, and machine readable format and to transfer those data to another party;
  • to object to any profiling; and
  • to not be subjected to any automated decision-making, including profiling.

For more information: see articles 15 through 20 of the General Data Protection Regulation.

How?

In case you participate in research, direct your request to the contact person mentioned in the informative letter.

In any other cases you can make your request by sending an email to info@trimbos.nl.

At the time you make such request to the Trimbos Institute, the Trimbos Institute will request you to:

  • fill in a form and send or email it to the Trimbos Institute;
  • provide data necessary to ensure you are the person listed in our records.

Upon receipt thereof the Trimbos Institute will process your request as soon as possible and we will respond in writing within four weeks after receipt of your request.

We can extend this term with another two months in case the number of requests and/or the complexity and the scope of it requires such.

In case you are not included in the Trimbos Institute records, the Trimbos Institute will inform you of such in writing and immediately erase the data you provided to us by means of the form.

Exception for scientific research

Based on the law, exercising your right to access, rectification, restriction of processing, and the right to erasure of data may be denied under certain circumstances if the personal data are being used exclusively for statistical or scientific purposes. It may be possible, should such circumstances occur, that the Trimbos Institute will exercise this right. In that case you will be informed about this.

11. Complaints?

Should you wish to put in a complaint about the use of your personal data you can contact our Data Protection Officer at fg@trimbos.nl.

The Data Protection Officer is independent and monitors compliance of the GDPR on behalf of the Trimbos Institute.

Should you not be satisfied with how the Trimbos Institute handles your complaint or should you rather not put in your complaint at the Trimbos Institute, you can also do this at the (Dutch) website of Data Protection Authority (DPA).

12. Changes

It is possible this Privacy Statement will be changed after some time. We will keep you updated about these changes by updating this web page. We therefore suggest you regularly check this page to inform yourself about any possible changes.

In case of changes to the Privacy Statement that we consider to be of a large scale, we will announce this for a period of time on this website.

The Privacy Statement was last updated May 25, 2018.

13. Links

The website of the Trimbos Institute may contain links to websites that have not been created by the Trimbos Institute and vice versa. The Trimbos Institute excludes any liability for the contents of these linked sites and for how these sites protect and handle your personal data. Use great discretion and check the Privacy Statement pertaining to that particular website

Disclaimer

This document is a translation of the Dutch original. In case of discrepancy, the Dutch original version shall prevail.