Privacy Statement – version 2023.1

2. Why does Validata process personal data?

Validata is specialised in screening individuals by means of a digital screening process. We process your personal data in order to perform a screening of relevant data at the request of a client.

3. What is Validata’s role under the GDPR?

meaning of the GDPR. This means that we process data on behalf and for the purposes of the organisation that requested the screening for you: the client (often your future employer).

We recommend reviewing the client’s privacy notice and screening policy. As a data controller, the client is best positioned to explain to you why you are being screened and why each of the screening components was chosen.

Did you request your screening from us yourself? If so, Validata is a data controller.

Our contact details are:

Validata Group BV

Address – Apollolaan 151, 1077 AR Amsterdam

Telephone – +31 (0)20 5356898

Email – info@validatagroup.com

Chamber of Commerce no. 34346504

Validata has a Data Protection Officer (‘DPO’) who is registered with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens). The DPO can be contacted via privacy@validatagroup.com.

4. On what legal basis does Validata process personal data?

The client determines the basis for screening. In some cases, for example, screening may be required by law; in other cases, the organisation requesting your screening has a legitimate interest. You can find more information about the legal basis of processing in the client’s privacy statement.

Did you request your screening from us yourself? Then we process your personal data because we need it to perform the screening. This data is necessary for the performance of a contract. We process payment data on the basis of Validata’s legitimate interest.

5. What personal data does Validata process?

For each screening, Validata processes the following personal data, which we receive from you or from our client:

• Data concerning your name and address, gender, email address and telephone number.

In addition, depending on the client’s screening policy and the resulting components of the screening, the following personal data and/or documents may be processed:

• Curriculum Vitae (CV);
• Date of birth, Place of birth, Nationality;
• Identity document: passport, (Dutch) identity card or Dutch document for foreigners;
• Driving licence;
• Certificate of Good Conduct (Verklaring Omtrent Gedrag ‘VOG’);
• Data concerning your educational background;
• Data concerning your work experience;
• Data provided by referees;
• Data from sector and/or professional registers;
• Data concerning your financial situation; including data from the register of persons under guardianship, data from the insolvency register, the ratio of your personal financial liabilities to your earnings or assets, and your credit rating;
• Data from declarations you have made, or from your integrity statement:

1. data concerning outside activities and/managerial positions;
2. data concerning circumstances that cast doubt on your reliability, competence or integrity;
3. data concerning convictions for a criminal or corporate offence or being treated as a suspect in an inquiry into a criminal or corporate offence;

• Data concerning legal entities: legal status, business information, financial information and/or managerial powers;
• Data from social media and/or public sources;
• Data from international terrorist watchlists, politically exposed persons (PEP) lists and sanctions lists, and;
• Data relating to additional documents that are gathered, verified or checked at the request of our client, such as a payslip, confidentiality statement, landlord statement, employer’s statement, disciplinary law statement (Verklaring Onderwerping Tuchtrecht ‘VOT’) and/or a code of conduct.

6. From whom does Validata receive personal data?

In order to perform specific components of a screening or to verify data, Validata receives personal data from the following parties:

• you;
• our client(s);
• data suppliers in the context of performing a screening;
• relevant educational institutions (within and/or outside of the Netherlands);
• relevant sector and/or professional registers, such as the BIG register (for healthcare professionals);
• employers and/or other persons submitted by you as referees.

7. With whom does Validata share personal data?

In order to perform specific components of a screening or to verify data, Validata shares the necessary personal data with the following parties:

• data suppliers;
• relevant educational institutions (within and/or outside of the Netherlands);
• relevant sector and/or professional registers, such as the BIG register (for healthcare professionals);
• employers and/or other persons submitted by you as referees;
• our client.

Finally, you will of course receive a copy of the screening report yourself.

8. With which data suppliers are personal data shared?

Validata has concluded agreements with its data suppliers that set out arrangements to ensure a correct and secure processing of your personal data. Validata’s data suppliers are:

• DUO
• Nuffic
• Qualifícation Check
• Mitek Systems
• Company.info
• Focum
• EDR
• Dun & Bradstreet
• DataExpert
• KvK (Chamber of Commerce)
• Kadaster

9. Are special categories of personal data processed?

In some cases, Validata processes special categories of personal data. This depends on which components are included in the screening. The components of the screening have been determined by the client based on its policies, taking into consideration the potential risks associated with a specific job, a membership, specific work activities, or with the rental or sale of a home. Prior to the screening, you will be informed about the (special categories of) personal data that need to be processed. Validata may also process criminal data on the instructions of clients.

Validata has a licence under the Act on Private Security Firms and Detective Agencies (POB): POB licence no. 1533. Based on this licence, and provided that certain conditions are met as set out in the GDPR, Validata may, if you request a screening yourself, also process data concerning criminal convictions or treatment as a suspect in a criminal inquiry.

10. Processing identity document (ID document)

Validata processes identity documents to enable our client to meet its legal obligation to verify a person’s identity. This involves checking the authenticity of a scan of the identity document based on a number of security features. In addition, the document number is checked to establish that the document has not been reported stolen or missing.

11. Is submitting to the screening mandatory?

You have the right not to be screened. Chances are though, that this limits your chances to enter upon a new agreement or position that requires a screening. If you object to (all or parts of) the screening or have any questions, please contact the client. After all, the client has determined the composition of the screening in its policy.

12. Is my data secure?

Validata has taken appropriate technical and organisational measures to protect personal data against loss or any form of unlawful processing.

13. How long will my data be stored?

Personal data is retained by default for 90 days after completion of the screening. After 90 days, personal data will be deleted unless the client specified a different retention period for storing personal data with Validata.

Did you request your screening from us yourself? Then we keep the data for 90 days to allow you to download the screening report. You can ask us to delete the data earlier.

14. Will my personal data be transferred to other countries within or outside of the EEA?

Validata processes your personal data within the European Economic Area (EEA). Under certain circumstances, (all or parts of) your personal data may be transferred to a ‘third country’ outside of the EEA. This is the case, for example, if you are based in third country outside of the EEA, or if the client, a data supplier, or another party with whom we share your personal data, is based in such a third country.

15. Please be advised of your (privacy) rights:

As a processor, Validata will forward all requests from data subjects to the client (the controller). You can also send your request directly to the client. Did you request your screening from us yourself? Then Validata, as the data controller, will process the request.

• Right of access: To access the personal data gathered on you by Validata, please login via your personal account at Validata.
• Right to rectification: To request changes or additions to the personal data gathered on you, please send an email to Validata.
• Right to erasure (‘right to be forgotten’): You can request Validata to erase your personal data from Validata’s systems; for example, if Validata no longer needs the personal data in the context of the business activities agreed with the client.
• Right to restriction of processing: You can request Validata to (temporarily) stop processing your personal data.
• Right to object: You can object to the processing of your personal data.
• Right to lodge a complaint: If you have a complaint about our services, you can lodge a complaint with Validata to our department Support via support@validatagroup.com.

Please also be advised that you can lodge a complaint with the Dutch Data Protection Authority about how the client or Validata handles your personal data.

If you have any queries concerning the above matters, please contact our department Support via support@validatagroup.com.

16. Version Privacy Statement

This Privacy Statement may change from time to time. On our website you always find the most recent version.