This privacy statement concerns the way in which personal data are collected and how they are handled by the TOP Foundation, as well as the rights of providers of personal data. This privacy statement has been drawn up in accordance with the General Data Protection Regulation.
- Personal data
The TOP Foundation processes personal data based on contracts, permission, and legitimate interest. The TOP Foundation needs personal data to be able to provide its services to TOP participants, TOP mentors, and TOP crew in TOP Week. The personal data provided by participants and mentors creating a TOP account, or by TOP crew completing Google Forms is used for various purposes.
1.1 Providing information
The TOP Foundation sends participants, mentors, and TOP crew information regarding TOP Week by using the personal data provided in the TOP account.
1.2 Creating a WhatsApp group
In the weekend before the start of TOP Week, the TOP Foundation sends names and phone numbers of TOP participants to TOP mentors so mentors can create a WhatsApp group. Participants are informed of this when they create a TOP account.
1.3 Registration for events
The TOP Foundation uses personal data for the registration of participants, mentors, and TOP crew to provide access to the events during TOP Week. Creating groups of participants and mentors by means of personal data is also part of the registration process.
1.4 Payment system for events
Personal data are linked to a personal RFID chip that can be used during TOP Week to make payments. The RFID chip is part of a digital, cashless payment system that is used by the TOP Foundation. During TOP Winter Week, the cashless payment system will not be used and no personal data will therefore be linked to a personal RFID chip.
1.5 The TOP Foundation makes audiovisual recordings during TOP activities for reporting and promotional purposes.
- Receivers of data
2.1 Tactile B.V.
Tactile B.V. is a company that facilitates the digital cashless payment system for the TOP Foundation. The TOP Foundation commissions Tactile B.V. to process the personal data van participants, mentors, and TOP crew based on a data processing agreement. Every participant, mentor, and crew member gets a personal account in a Tactile web application. Through the account in the web application, personal data are linked to a personal RFID chip, that can be used to make payments during TOP Week. Tactile destroys all data when the contract expires. During TOP Winter Week, the cashless payment system will not be used and no personal data will therefore be linked to a personal RFID chip.
2.2 3WA Registration system
The personal data provided when creating a TOP account is automatically stored in the 3WA registration system. The TOP Foundation and the administrator of the TOP registration system have access to the personal data stored on the 3WA server.
The SendinBlue platform is used to provide participants and mentors with information via e-mail. SendinBlue has access to the first names and e-mail addresses of participants and mentors as soon as they are used for sending e-mails. Agreements have been set out on the use of the data in a data processing agreement with SendinBlue.
2.4 Study and student associations
The 3WA registration system included an option to participate get more information about study associations, student associations, Swapfiets and/or buying a ‘Studentenbox’ via TOP. If TOP participants explicitly indicate in the 3WA registration system the wish to get more information and/or want to buy a ‘Studentenbox’, their personal data will be shared with the relevant party. Furthermore, Magister JFT, the MAK Mentorship System, IDEA and I*ESN will have access to the data of the mentors and participants relevant to them. These parties are responsible for the annual program after TOP Week. Furthermore, Magister JFT, the MAK Mentorship System, IDEA and I*ESN will have access to the data of the mentors and participants relevant to them. These parties are responsible for the annual program after TOP Week. During TOP Winter Week, personal data of partcipants will be shared with student association I*ESN Tilburg for the purpose of making group divisions.
- Storage period
Personal data will be stored in the registration system for a maximum period of five years after the TOP account is created. In this five-year-period, there is the possibility that the TOP account is used by the participant or mentor to reregister.
The TOP Foundation does not make any physical copies of personal data. The data are only managed in above-mentioned systems.
The personal data and the applications managed by the TOP Foundation are adequately secured.
- Rights of the data subjects
a. Right to access
Participants, mentors, and TOP crew have the right to access their data stored by the TOP Foundation at all times, either by e-mail or through telephone contact. An overview of the stored data will be shared with the participant, mentor, or TOP crew member.
b. Right to rectification
If data are incorrect or have changed, the data subject has the right to have them rectified by the TOP Foundation.
c. Right to transfer
If the data subject switches to a different party or service, the data subject has the right to have his/her data stored by the TOP Foundation transferred. The TOP Foundation must transfer all data to the other party.
d. Right to have data removed
The data subject has the right, at all times, to have personal data removed.
e. Right to lodge a complaint
Data subjects have the right to lodge a complaint with the Dutch Data Protection Authority if he/she is of the opinion that the TOP Foundation has infringed his/her rights under the Regulation.
f. Right to stop the data processing (objection)
Data subject have the right to ask the TOP Foundation to stop using their personal data.
The TOP Foundation will never share personal data with third parties other than for the purposes referred to in this privacy statement. The required data are the minimum data required for the provision of services by the TOP Foundation. If these required data are not provided, the TOP Foundation cannot offer its services.
The TOP Foundation reserves the right to share data if it is legally bound to do so or if the TOP Foundation considers it justified to do so to meet a legal request or to protect the rights, property, or security of the TOP Foundation. In doing so, the TOP Foundation will always try to respect the right to privacy of TOP participants, TOP mentors, and TOP crew as much as possible.
Adopted by the Board of the Tilburg Orientation Program Foundation on October, 2020.