This privacy statement was last amended on January 28, 2020.
SPF is what is referred to as the ‘controller’ within the meaning of the General Data Protection Regulation (GDPR). In this role, SPF determines which personal data are processed, the purpose of the processing, and the means of the processing.
SPF is responsible for ensuring that your personal data are processed in accordance with the GDPR and in a proper and prudent manner.
SPF 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.
SPF 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
SPF 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. SPF 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. SPF has also concluded an administration agreement with SABIC for the administration of SABIC's pension agreement. SPF must also process personal data to administer the administration agreement in the appropriate manner.
Security of personal data
Article 32 of the GDPR requires SPF to implement appropriate technical and organizational measures to prevent loss of personal data or unlawful processing.
Personal data retention period
SPF does not retain your personal data for longer than is necessary for the purpose of the processing (Article 5(1)(e) of the GDPR). SPF 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 SPF processes, you can submit a written access request. SPF 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 SPF, 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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