This privacy statement was last amended on January 28, 2020.
PDN is what is referred to as the ‘controller’ within the meaning of the General Data Protection Regulation (GDPR). In this role, PDN determines which personal data are processed, the purpose of the processing, and the means of the processing.
PDN is responsible for ensuring that your personal data are processed in accordance with the GDPR and in a proper and prudent manner.
PDN processes personal data within the meaning of Article 4(1) of the GDPR. Personal data are any data that can provide information about an identified or identifiable natural person.
PDN processes personal data to perform the pension agreement in the appropriate manner. These personal data are classified in categories including the following:
Basis for processing
PDN must be able to base its processing of these personal data on a basis specified in Article 6 of the GDPR. Pursuant to this Article, processing of these data is permitted for reasons including processing that is necessary to perform an agreement or is necessary for compliance with a legal obligation. PDN is a pension fund within the meaning of Article 1 of the Pensions Act (Pensioenwet) and, pursuant to the Pensions Act, must process some data to perform its duties in accordance with the Act. PDN has also concluded an administration agreement with DSM Nederland BV for the administration of DSM Nederland BV's pension agreement. PDN must also process personal data to administer the administration agreement in the appropriate manner.
Security of personal data
Article 32 of the GDPR requires PDN to implement appropriate technical and organizational measures to prevent loss of personal data or unlawful processing.
Personal data retention period
PDN does not retain your personal data for longer than is necessary for the purpose of the processing (Article 5(1)(e) of the GDPR). PDN bases this on the Federation of the Dutch Pension Funds’ Servicedocument Bewaartermijnen van de Pensioen (retention periods for pension service documents)
Your privacy rights
You have the right to access your personal data (Article 15 of the GDPR) and the right to the rectification or erasure of your personal data (Articles 16 and 17 of the GDPR).
If you would like to know which of your data PDN processes, you can submit a written access request. PDN will process your request within a reasonable period.
If you see that your data are incorrect, incomplete, or irrelevant, you can submit a supplementary request for the rectification or supplementation of your data (Article 16 of the GDPR). In some cases, you can request the erasure or deletion of your data (Article 17 of the GDPR).
If you wish to receive your personal data (in digital or non-digital form) as processed by PDN, you can invoke your right to data portability (Article 20 of the GDPR). You will then receive your data in a format that you can readily transmit to another organization if you so wish. You can also request a restriction of the processing of your data or lodge an objection to this processing (Articles 18 and 21 of the GDPR).
You can submit your request, in writing, to Postbus 6500, 6401 JH Heerlen.
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