Privacy Statement

ABN AMRO Pensioenfonds is an independent foundation responsible for the administration of the pension plans of the companies affiliated with it. In this context, ABN AMRO Pensioenfonds processes personal data relating to members and deferred members. ABN AMRO Pensioenfonds treats your personal data with due care. The processing of your personal data takes place within the context of data protection legislation and sound and controlled operational policies and processes.

In this Privacy Statement, we explain what personal data we process, why we process your personal data, how we treat your personal data and what your rights are.

This Privacy Statement forms part of the data protection policy of ABN AMRO Pensioenfonds. The data protection policy sets out the arrangements made by ABN AMRO Pensioenfonds with regard to data protection.

What personal data do we process?

We only process personal data that is relevant to what we do. By personal data, we mean information that can be used to identify you, either directly or in combination with other information. This includes the following data:

  • Name and initials
  • Date of birth and death
  • Citizen service number (BSN)
  • Address, place and country of residence
  • Mailing address
  • Gender
  • Partner or ex-partner (if applicable)
  • Date of marriage/divorce or date of start of co-habitation/separation
  • Employment details, salary details, pensionable allowances and part-time factor
  • Details on capacity for work
  • IBAN
  • Communication and newsletter preferences
  • Email address
  • Telephone number
  • Test calculations in the Pension Planner

Why do we process your personal data?

Most processing operations are necessary to fulfil our obligations. To illustrate, we must comply with pension laws and regulations and the ensuing pension plan and administration rules. In this context, we process your personal data for the following purposes:

  • To provide our services to you. Examples:
    • We determine the level and payment of your pension
    • We calculate, record and collect contributions
    • We provide you with timely information, for example through email alerts
  • To deal with disputes, complaints or litigation.

    We also process personal data to protect our legitimate business interests We do this for the purpose of further improving our services (e.g. by performing statistical analyses) or to investigate suspicions of wrongdoing such as fraud.

    In some cases, we need your consent to process personal data, such as your preferences concerning our newsletter in order to send you general information.

Whose personal data do we process?

We process the data of:

  • Members and deferred members
  • Pensioners
  • Partners, ex-partners and orphans (if entitled to an orphan’s pension) of members or pensioners
  • Other interested parties, such as a judgment creditor

From whom do we receive the personal data we need?

We receive the personal data we need from:

  • You or your legal representative
  • Your employer
  • The Personal Records Database/Non-Residents Records Database
  • The Employee Insurance Administration Agency (UWV)
  • Bailiffs and other authorised parties who administer claims against members
  • CAK (for the withholding of health insurance contributions under the Dutch Health Insurance Act (ZVW) for pensioners living outside the Netherlands and in Europe)
  • Previous pension providers

Which parties do we give access to your personal data?

We may share your personal data in the following circumstances:

  • Our employees can obtain access to your personal data for the performance of their work. They will only receive access to your personal data for the above purpose.
  • Third parties who process your personal data on our behalf. Examples:
    • The vendor of our pension administration system
    • The company that sends our mail
    • Our supplier for paying pensions
    • The supplier of data from the Personal Records Database (BRP)
    • Our office automation supplier
    • Bailiffs for the collection of receivables
    • Vendors of communication tools, such as for the
    • client panel.

Such third parties can only process your personal data for the above purposes and only in accordance with our instructions.

  • Where necessary to comply with rules and regulations, we may provide personal data to such bodies as municipal authorities, the tax authorities, Statistics Netherlands (CBS), the police, judicial authorities, supervisory authorities and court bailiffs (e.g. in the case of attachments).
  • If you have authorised a natural person, institution or organisation to request us to provide them with your personal data.

    We do not transmit your personal data to countries outside the European Economic Area (EEA). The EEA comprises all EU countries plus Liechtenstein, Norway and Iceland.

What measures do we take to ensure the security and confidentiality of your personal data?

We are committed to the protection of your personal data. For this reason, we have taken appropriate technical and organisational measures to protect your personal data against theft, loss or other unlawful use. The pension fund has also put in place management procedures to make sure that the information remains accurate and complete. We operate in accordance with these management procedures. For a summary of your pension at ABN AMRO Pensioenfonds, please go to ‘Mijn Pensioen’. You can only log in with your DigiD user name and password plus an extra code that will be sent to you by text message or via the DigiD app.

How long is your personal data retained?

Your personal data is only retained for as long as necessary for the purpose for which it was collected or is processed. We retain some data for a longer period because we are legally required to do so. In that case, we adhere to the statutory retention period.

  • In the case of accrued rights, we will retain your personal data for up to seven years after the last beneficiary (e.g. partner or orphan) has died.
  • If your relationship with ABN AMRO Pensioenfonds ended before your retirement, e.g. if your accrued benefits have been transferred, we will retain your data for up to 20 years to help us assess any disputes about rights.
  • Data to improve our communications about our services, such as analytical data and information from the client panel, is retained for up to five years.

What are your rights regarding your personal data? 

You can view, and in some cases change, your data in ‘Mijn Pensioen’. You can also use the contact details below to submit a request to exercise the following rights concerning your personal data. Before considering your request, we may ask you to provide further information in order to verify your identity. If we reject your request, we will give the reasons for the rejection.

Right of access

You have the right to request a copy of your personal data that we have and certain information about our use of this data.

Right to rectification

We take reasonable measures to ensure that the personal data we have about you is accurate and complete. You can request us to update or change your personal data.

Right to erasure

You have the right to ask us to erase your personal data, for instance if we no longer need your personal data in relation to the aforementioned purposes or if you withdraw your consent for processing, or if you rightfully object to a processing operation that we carry out in order to protect our legitimate interests. A request to erase personal data is weighed up against other factors. We may, for instance, be under a legal obligation to retain your personal data.

Right to restriction of processing

You have the right to request us to restrict the processing of your personal data, for instance if you think that the personal data is inaccurate. The restriction will then apply for the duration of the period we require to verify the accuracy of the data. If you object to processing, you can also request that processing is restricted while you await the decision on your objection. You then have the right to the restriction of processing of personal data if that processing is unlawful but you do not wish to erase the relevant data, or if you still require the personal data but ABN AMRO Pensioenfonds no longer does.

Restriction of processing means that the relevant personal data cannot be processed. Processing is, however, permitted in the following situations:

  • If your personal data is no longer required and is only retained
  • If you have given consent
  • In the event of legal claims, for the protection of the rights of another natural or legal person or for reasons of important public interest of the EU or of a Member State

We will inform you before a processing restriction is lifted.

Right to object

You have the right to object to the processing of personal data that is based on our legitimate interest. Unless we have compelling grounds for such processing, we will no longer process your personal data on the grounds of this legal basis if you lodge an objection.

Right to withdraw your consent

You have the right to withdraw your consent for the receipt of general communications, such as our newsletter.

Right to data portability

Insofar as legally applicable, you have the right to receive your personal data, or, where technically feasible, to arrange for your personal data to be transmitted to a third party, in a structured, commonly used and machine-readable format. This right relates only personal data that concerns you and that you provided to us.

Right to lodge a complaint with the supervisory authority

You have the right to lodge a complaint about the processing of your personal data with the Dutch Data Protection Authority (Dutch DPA), for example if you believe that ABN AMRO Pensioenfonds violated your privacy when using your personal data. See: https://autoriteitpersoonsgegevens.nl/nl/zelf-doen/privacyrechten/klacht-indienen-bij-de-ap

Right not to be subject to automated individual decision-making

Automated decision-making is said to exist if information that has been obtained is enriched automatically (without any human intervention) using “own opinions”, following which the data subject is classified using a profile. This profile is then used as the basis for further processing (profiling).

As ABN AMRO Pensioenfonds does not make use of automated decision-making and profiling, you cannot invoke this right.

Cookies

ABN AMRO Pensioenfonds makes use of cookies on the website www.abnamropensioenfonds.nl. Cookies are small text files that are sent to your browser and saved on your computer, mobile telephone or tablet when you visit our website. Below you can read which cookies we use when you visit this website and how you can disable cookies.

Functional cookies

Functional cookies are essential for the website to work. We use these cookies so that you can select a language and can log in.

Analytical cookies

We use analytical cookies to measure how many visitors look at our website, which sections are viewed the most and which percentage of recipients read the newsletter. The collected statistical information is used to tailor the content on the website and our newsletter to the needs of visitors or readers. We make use of Google Analytics (https://www.google.com/policies/technologies/cookies/).

We have signed a processing agreement with Google; this agreement formalises the protection of your personal data. We make no use of other Google services in combination with Google Analytics cookies and have switched off the data sharing option, so that Google does not share your data or use it for its own purposes, such as advertising. We have also agreed with Google that the last octet of your IP address is obscured before being saved by Google.

The use of Google Analytics cookies means that personal data might be transmitted to the United States. If so, the personal data is adequately protected by the EU-US Privacy Shield. You can read more about this privacy shield at www.privacyshield.gov.

Disabling cookies

You can change the settings of your browser to erase placed cookies and reject the placement of new cookies. The procedure for disabling cookies depends on your browser. Please consult the Help function of your browser for more details. If you opt not to accept cookies, our website may not work properly.

Changes

We may change this Privacy Statement and advise you to consult this page from time to time. This Privacy Statement was last updated on 2 January 2019. 

Contact

Contact us by email at privacy@abnamropensioenfonds.nl:

  • If you have questions about this Privacy Statement
  • If you have questions about how we process personal data
  • If you wish to exercise your rights concerning your personal data