Data Protection Policy - DGM-SDG

Data Protection Policy

Safeguarding collected data in compliance with EU GDPR (General Data Protection Regulation)

1. INTroduction

DGOffice B.V. needs to collect and use certain types of information about the Individuals or Service Users who come into contact with DGOffice order to carry on our work. Also business information like shipment information or product details is collected. This information must be collected and dealt with appropriately whether is collected on paper, stored in a computer database, or recorded on other material and there are safeguards to ensure this under the EU General Data Protection Regulation (GDPR) (Implemented in the Netherlands as AVG – Algemene verordening gegevensbescherming).

2. Data Controller

Although DGOffice B.V. is, based on the data we collect, not required to appoint a Data Controller under the regulation, DGOffice B.V has appointed a Data Controller in general to make sure compliance is monitored in relation to GDPR.

3. Disclosure

DGOffice B.V. may share data with other agencies such as the local authority, resellers or other third parties working on its behalf.

The Individual/Service User will be made aware in most circumstances how and with whom their information will be shared.  There are circumstances where the law allows DGOffice B.V. to disclose data (including sensitive data) without the data subject’s consent.

These are:

  1. Carrying out a legal duty or as authorised by the Secretary of State.
  2. Protecting vital interests of an Individual/Service User or other person.
  3. The Individual/Service User has already made the information public.
  4. Conducting any legal proceedings, obtaining legal advice or defending any legal rights.

DGOffice B.V. regards the lawful and correct treatment of information as very important to successful working, and to maintaining the confidence of those with whom we deal.

DGOffice B.V. intends to ensure that information is treated lawfully and correctly.

To this end, DGOffice B.V. will adhere to the Principles of Data Protection, as detailed in the EU GDPR / NL AVG.

Specifically, the Principles require that information:

  1. Shall be processed fairly and lawfully and, in particular, shall not be processed unless specific conditions are met.
  2. Shall be obtained only for one or more of the purposes specified in the Regulation, and shall not be processed in any manner incompatible with that purpose or those purposes.
  3. Shall be adequate, relevant and not excessive in relation to those purpose(s).
  4. Shall be accurate and, where necessary, kept up to date.
  5. Shall not be kept for longer than is necessary.
  6. Shall be processed in accordance with the rights of data subjects under the Regulation.
  7. Shall be kept secure by the Data Controller who takes appropriate technical and other measures to prevent unauthorized or unlawful processing or accidental loss or destruction of, or damage to, information.
  8. Shall not be transferred to a country or territory outside the European Economic Area unless that country or territory ensures an adequate level of protection for the rights and freedoms of Individuals/Service Users in relation to the processing of information.

DGOffice B.V. will, through appropriate management and strict application of criteria and controls:

  • Meet its legal obligations to specify the purposes for which information is used.
  • Collect and process appropriate information, and only to the extent that it is needed to fulfill its operational needs or to comply with any legal requirements.
  • Ensure the quality of information used.
  • Ensure that the rights of people about whom information is held, can be fully exercised under the Regulation. These include:
    • The right to be informed that processing is being undertaken.
    • The right of access to one’s information.
    • The right to prevent processing in certain circumstances and
    • The rights to correct, rectify, block or erase information which is regarded as wrong information.
  • Take appropriate technical and organizational security measures to safeguard information.
  • Ensure that information is not transferred abroad without suitable safeguards.
  • Treat people justly and fairly whatever their age, religion, disability, gender, sexual orientation or ethnicity when dealing with requests for information.
  • Set out clear procedures for responding to requests for information.

4. Data Collection

Informed consent is when:

  • An Individual/Service User clearly understands why their information is needed, who it will be shared with, the possible consequences of them agreeing or refusing the proposed use of the data.
  • And gives their consent.

DGOffice B.V. will ensure that data is collected within the boundaries defined in this policy. This applies to data that is collected in person, or by completing a form.

When collecting data, DGOffice B.V. will ensure that the Individual/Service User:

  • Clearly understands why the information is needed.
  • Understands what it will be used for and what the consequences are should the Individual/Service User decide not to give consent to processing.
  • As far as reasonably possible, grants explicit consent, either written or verbal for data to be processed.
  • Is, as far as reasonably practicable, competent enough to give consent and has given so freely without any duress.
  • Has received sufficient information on why their data is needed and how it will be used.

5. Data Storage

Information and records relating to service users will be stored securely and will only be accessible to authorised staff and third parties.

Information will be stored for only as long as it is needed or required statute and will be disposed of appropriately.

It is DGOffice B.V. responsibility to ensure all personal and company data is non-recoverable from any computer system previously used within the organisation, which has been passed on/sold to a third party.

6. Data Access and Accuracy

All Individuals/Service Users have the right to access the information holds about them. DGOffice B.V. will also take reasonable steps ensure that this information is kept up to date by asking data subjects whether there have been any changes.

In addition, DGOffice B.V. will ensure that:

  • It has a Data Protection Officer with specific responsibility for ensuring compliance with Data Protection.
  • Everyone processing information understands that they are contractually responsible for following good data protection practice. 
  • Everyone processing information is appropriately trained to do so. 
  • Everyone processing information is appropriately supervised. 
  • Anybody wanting to make enquiries about handling information knows what to do.
  • It deals promptly and courteously with any enquiries about handling information. 
  • It describes clearly how it handles information. 
  • It will regularly review and audit the ways it hold, manage and use information. 
  • It regularly assesses and evaluates its methods and performance in relation to handling information. 
  • All staff are aware that a breach of the rules and procedures identified in this policy may lead to disciplinary action being taken against them.

7. Data Security Breach

Upon detection of an incident or potential incident involving Individuals or Service Users data that has or may have been lost, stolen, improperly changed, or otherwise accessed or compromised, DGOffice B.V. shall notify the Individuals or Service Users within 7 days after the breach was noticed or according to appropriate laws.  The initial notification shall include all relevant details of the incident.  Follow-up reporting will include the details that led to the incident and the remediation plan and its status.

Data Protection Officer

This policy will be updated as necessary to reflect best practice in data management, security and control and to ensure compliance with any changes or amendments made to the EU Data Protection Directive.

In case of any queries or questions in relation to this policy please contact the DGOffice B.V. Data Protection Officer:

Richard C-O. Kure

Data Protection Officer


Herman Teering

Managing Director & Principal Consultant

Date: 30 November 2012

Review Date: 1 May 2018

Glossary of Terms

Data Protection Officer

The person(s) responsible for ensuring that DGOffice B.V. follows its data protection policy and complies with the EU Data Protection Directive.

EU Data Protection Directive

The EU legislation that provides a framework for responsible behaviour by those using information. The Netherlands implemented the EU Data Protection Directive 95/46/EC on 1 September 2001 with the Dutch Personal Data Protection Act (“Wbp”). Enforcement is through the Dutch Data Protection Authority (“College Bescherming Persoonsgegevens”).

Explicit Consent

Is a freely given, specific and informed agreement by an Individual/Service User in the processing of information about her/him or her/his company. Consent is needed for processing sensitive data and is also given by accepting the User Agreement incorporated in our services.

Individual/Service User

The person or company whose information is being held or processed by DGOffice B.V., for example: a client, an employee or shipment information.


Information about living individuals that enables them to be identified – e.g. name and address. It does also apply to information about organisations, companies, agencies and their activities.


Means collecting, amending, handling, storing or disclosing information.


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