Privacy statement

RSW Accountants + Adviseurs, which has its registered office at Stapelovenweg 2, 5708 JW Helmond (NL), is responsible for processing personal data such as that listed in this privacy statement.

Contact details

Website: www.rsw.nl

Address: Stapelovenweg 2, 5708 JW Helmond

Phone: 0492550775

Chantal Goossens is the RWS Data Protection Officer . You can contact her via chantal.goossens@rsw.nl

The personal data that we process

RWS processes your personal data because you use our services and/or because you have provided that data to RWS.

An overview of the personal data that we process is given below:

• Initials, first name and surname
• Sex
• Date of birth
• Place of birth
• Marital status
• Place of residence
• Address details
• Phone number
• E-mail address
• Bank account number

When you visit www.rsw.nl, data about your surfing behaviour, internet browser and device type are recorded to let us improve our website. This does not include any other personal data.

Special and/or sensitive personal data that we process

RSW may process special and/or sensitive personal data about you. This is :

• A copy of an identity card or passport, including the BSN (citizen service number). This is for the WWFT (Anti-Money Laundering and Anti-Terrorist Financing Act) and for implementing our services. Photos, document numbers and machine-readable zones (MRZ) are blacked out before they are recorded in our systems.
• Business financial data showing income and purchasing behaviour. We do not need details of private transactions for our services, but these are recorded in some cases to replace other overviews.
• For income tax returns, we may also process data of minors aged under 16. This includes initials, first name, surname, date of birth and BSN (citizen service number). These are only recorded if they are strictly necessary for implementing our services for the tax returns in question. If the clients for whom we provide payroll administration services employ minors, the place of birth is also recorded. The parents or guardian must have consented to the child’s employment.

Why we process personal data and on what grounds

RSW processes your personal data for the following purposes:

• To be able to call or e-mail you in the context of implementing our services.
• To inform you about changes in our services and products.
• To send our newsletter and/or advertising folder.
• To deliver goods and services to you.

RSW also processes personal data if we are legally obliged to do so, such as the data we need for a tax return. E-mails are also recorded if they include important communications. Only the e-mail traffic that is deemed necessary and/or important is recorded in the client dossier.

We typically receive data from our clients to let us provide our services. In most cases, we are the controller for processing this data. However, in the rare cases where we act as the processor, you can find the relevant processing agreement on this page.

Automated decision-making

RSW does not make decisions about matters that could significantly affect individuals on the basis of automated processing. This includes decisions made by computer programs or systems, without intervention by a human (e.g. an RSW employee).

Retention period for personal data storage

RSW stores your personal data for no longer than strictly necessary to realise the objectives that your data has been collected for. We use the following retention periods for the following personal data (or categories thereof):

• We store client data for up to 10 years after the business relationship ends. The legally required retention period is 7 years unless there are contractual agreements or in the case of data about property/real estate. In such cases, the data must be retained for 10 years. This also includes the personnel dossiers that we build up on behalf of our clients for payroll purposes. All data is destroyed after 10 years.
• Other data that is used for marketing purposes is stored for 1 year at most. In the case of an event, we delete the data within 1 year after the event ends. The data is either deleted within this period or anonymised so that it cannot be traced back to an individual. If you are a client and you visited an event, this fact is recorded in the client dossier.
• Job applications are kept for up to 4 weeks following completion of the application process. If explicit permission is given, this data may be stored for 1 year. This lets us use the data for future job vacancies.
• Camera images are stored for 3 months. These images are exclusively accessible to RSW employees and are only viewed upon request from management. In the case of an incident, the images are stored until the incident is resolved with the relevant agencies.

Sharing personal data with third parties

RSW does not sell your data to third parties and only provides it when necessary for fulfilling the agreement with you or to comply with a legal obligation. We sign processing agreements with companies that process your data to ensure the same level of security and confidentiality of your data. RSW remains responsible for this processing. Examples of parties we share data with:

• Software suppliers and cloud services
• Financial and business services, for payment service providers/banks
• Governmental bodies if there is a legal obligation to do so (for example the Tax and Customs Administration for tax returns)
• External experts within RSW’s network who have been engaged by RSW and/or on instructions from the client. These include lawyers, quality assessors and professional organisations.

Cookies and e-mail marketing

RSW uses functional, analytical and tracking cookies. A cookie is a small text file that is stored by the browser of your computer, tablet or smartphone when you first visit a particular website. RSW uses cookies that have purely technical functionality. They make sure the website works as it should and that your preferences are remembered. These cookies are also used to make sure the website works properly and to optimise it. Additionally, we place cookies that track your surfing behaviour so that we can offer tailored content.

We informed you about these cookies and asked for permission to store them when you first visited our website. You can opt out of cookies by setting your internet browser to stop storing cookies. You can also go via the settings of your browser to delete all information that it previously stored.

For an explanation, see (in Dutch) https://veiliginternetten.nl/themes/situatie/cookies-wat-zijn-het-en-wat-doe-ik-ermee/

Additionally, we share your data with analytical platforms; in these cases, only your internet browser and device type are recorded. This data is used for improving our website.

All our clients get subscribed automatically to our newsletters. There is a button at the end of every e-mail for unsubscribing from these mailshots. RSW reserves the right to send mail relating to our services or the execution thereof. You will still receive these even if you have unsubscribed from our marketing mailshots.

Inspecting, modifying or deleting data

You have the right to view your personal data or have it corrected or deleted. You also have the right to withdraw any consent given for processing the data or to object to the processing of your personal data by RSW, and you have the right to data portability. This means that you can ask RSW to send the personal data we have about you to you or another organisation named by you as a computer file.

You can submit a request to our Data Protection Officer for inspection, correction, deletion or transfer of your personal data or for withdrawal of your consent to the processing of your personal data or an objection to the same.

To ensure that the request for inspection is being made by you, we ask that you include a copy of an identity document. In this copy, you should black out your passport photo, MRZ (machine-readable zone, the strip with numbers at the bottom of the passport), document number and citizen service number. This is to protect your privacy. We will respond to your request as quickly as possible and in any event within four weeks.

RSW would also like to point out that you have the option of filing a complaint with the national supervisory body, the Dutch Data Protection Authority. You can do that using this link: Submitting a tip-off or a complaint to the Dutch DPA | Autoriteit Persoonsgegevens

How we secure your personal data

RSW takes protecting your data seriously and will take appropriate measures to prevent misuse, loss, unauthorised access, unwanted disclosure and unauthorised modification. Our security measures include:

• Backup and recovery procedures.
• Security for network connections.
• Authorisation is given to a limited number of people who are entrusted with the processing (including periodic checks).
• Encryption of personal data during electronic transfer to external parties.
• The security policy as implemented (including periodic checks and implementing changes to the policy).
• Code of conduct as implemented.
• Confidentiality statements in employment contracts.
• Intruder alerts.
• Logical access control using a username and password, with two-step verification where possible.
• Processing agreements with third parties.
• Safe methods of storing data files.
• Security software, such as a virus scanner and firewall.
• TLS (formerly SSL): we send your data over a secure internet connection.
• DKIM, SPF and DMARC are three internet standards that we use to prevent you from receiving e-mails on our behalf that contain viruses, are spam, or are intended to obtain personal (login) data.

If you feel that your data is not properly secure or if there are any signs of misuse, please contact our Data Protection Officer.

Updated: August, 19 2024