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Privacy policy
Privacy and data protection
The centres of expertise of Nuffic and SBB together form the organisation for International Credential Evaluation (IDW). We operate on behalf of the Ministry of Education, Culture and Sciences and the Ministry of Social Affairs and Employment. Through the process of credential evaluation, IDW processes personal data.
IDW handles personal data confidentially and with due care. Personal data is stored in a secure environment. IDW processes personal data in accordance with legislation relating to personal data. This includes the General Data Protection Regulation (GDPR) and ePrivacy rules.
Below, we describe what personal data we collect, why, how long we store your data,what the legal basis is for the processing and how you can contact us with any privacy questions.
What personal data do we process?
Personal data is any information relating to an identified or identifiable natural person ('data subject'); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person; The processing of personal data relates to all actions which can be undertaken by an organisation with regard to personal data, from collection through to anonymisation and deletion.
Which personal data does IDW process?
In the framework of its service provision, IDW processes the following personal data:
- First names and family name
- Gender
- Date of birth
- Email address
- Telephone number
- Bank account number (If applicable)
- Login details
- Information relating to diploma evaluation
- Information relating to study programme(s) completed
- Copy of diploma and grade list or list of subjects and possible translations
- Copy of notice of compulsory naturalisation (if applicable)
- BSN number (Citizens Service Number) (if applicable)
- Copy of proof of identity
Purposes
IDW processes personal data for the purpose of evaluating diplomas and/or certificates obtained and/or study courses followed abroad.
IDW can process diplomas or certificates in two distinct processes:
- As part of a mandatory trajectory to obtain Dutch citizenship (inburgering).
- At the request of people that wish to have the value of their diploma or certificate compared with the Dutch equivalents. You can also file your request through an authorised representative, such as a company.
In order to produce reliable and consistent evaluations, IDW retains all diplomas and certifications for a period of 7 years, and uses these as comparison material for new evaluations. IDW also processes and retains all evaluations for this purpose.
Legal bases
IDW processes personal data on the following distinct legal bases:
- for the performance of integration in the Netherlands carried out on behalf of the Ministry of Education, Culture and Sciences and the Ministry of Social Affairs and Employment. This task is based on the Civic Integration Act and the Integration procedure and necessary to comply with a legal obligation (Article 6(1) c of the GDPR.). We share your application and the results of your application with the Dutch ministry (through its subsidiary DUO).
OR
- for the purpose of the legitimate interests pursued by the centres of expertise of Nuffic and SBB (Article 6(1)f of the GDPR). We have ensured that our necessity to process your personal data prevails over your fundamental data protection rights by only requesting the minimum necessary data. We are studying the possibility to retain fewer data by only retaining a sample of credentials we frequently receive. If we want to use your personal data for any other purpose, we will first ask for your unequivocal and free consent for that specific activity. (Article 6(1) a of the GDPR).
Retention period
We store your data for as long as necessary for our service provision and to account for our activities. For this purpose, IDW maintains a storage period of 3 years. Scans of identifications documents are automatically deleted from our system twelve weeks following the completion of your last application.
Moreover, for a number of items of data, we are bound by statutory storage periods determined in financial or fiscal regulations. These storage requirements do not exceed a period of 7 years after your application.
Following expiry of the storage periods we remove all personal data.
Your rights in respect of your personal data
Access Request
You can at all times submit a written request to access all your personal data processed by us. If you submit such a request, for identification purposes we will request data from you that will enable us to determine that you are the person in our files. These data will be deleted immediately after having processed your request.
At the latest within four weeks following your request you will receive a written reply. We will then inform you:
- whether we are using your personal data and if so, which data
- why we are using your data
- with whom we may have shared your data
- the origin of your data, if known to us
Rectification, restriction and erasure
You yourself are able to alter your personal data (in other words for example name and date of birth) in the digital profile you can access with the user name and password you created when filing your application. Ensure that the information in your profile is always up to date. For those items of personal data that you are not able to change yourself you can submit a request to us to rectify your personal data if your data are incorrect or incomplete, are irrelevant or are used in contravention of the law. We will then rectify your data as quickly as possible. You can also submit a request to us to restrict the use of your data. This means that your data will be ‘decommissioned’ until it is clear whether their processing is lawful.
If you wish to have your data erased from our files, you can also submit a request for erasure to us. You will then receive a confirmation of your request stating the actions we will take in order to erase your data. It may not be possible for us to erase your data or that erasure is not permitted for example on the basis of a statutory obligation. In that case, we will duly notify you in the confirmation of your request.
You can exercise your rights by sending an email with a request to info@idw.nl.
Complaints and objections
In addition to exercising your statutory rights, you can at all times submit a complaint or an objection to the use of your personal data. Please contact our Data Protection Officer. You can also contact the Data Protection Officer for questions about this privacy statement. Our DPO can be reached at: fg@s-bb.nl.
If you have a complaint about the use of your personal data or you are unsatisfied about the way our DPO has responded, you can contact the Personal Data Protection Authoritity (Autoriteit Persoonsgegevens). See: https://autoriteitpersoonsgegevens.nl/en for the contact details.
Sharing of personal data
IDW will generally only share your personal data with third parties that are engaged as (sub)processors of IDW. We contractually guarantee they may only process the personal data for our purposes and take appriopriate security measures.
There are two exceptions to this rule:
- When we contact the institution that has provided your credentials. These institutions are independent data controllers.
- When we provide information to DUO about the number of requests processed to obtain Dutch citizenship and the id document number of the involved applicants (BSN nummers).
Our three (sub) processors are:
- Our IT supplier,
- Our translation agency, when necessary to understand your credentials
- A company that signs the PDF with the evaluation
If we are required by law and receive a valid order, we can be obliged to hand over personal data to law enforcement authorities. We will carefully examine any such requests.
We do not sell, trade or rent out your personal details to third parties.
Security
IDW takes every possible measure to prevent data breaches and other security incidents. With that in mind we have taken organisational and technical measures.
IDW has a strong security posture. IDW is committed to protect the integrity, availability and confidentiality of all data we process, If we engage third parties as data processors, we contractually guarantee strong security arrangements.
Alteration
This Privacy Statement is subject to alteration. If we would want to materially change the content of this policy to your disadvantage, we will first inform you in a timely manner for you to object, and where necessary, we will seek your prior unequivocal consent. Minor alterations are published on the IDW website.