Privacy Statement

The privacy statement below applies to the services provided by Bosveld bailiffs and debt collection. The services we perform for our clients in which your data is transferred. The privacy statement for our websites can be found here find.

1. Introduction

In our debt collection work, we use personal data about you. In this
privacy statement, we explain what personal data we collect, use and
retain and for what purpose.

Bosveld Bailiffs & Collections B.V. (hereinafter referred to as ‘Bosveld’) is responsible for the use of your data. In doing so, we must comply with the applicable laws and regulations. For example:

Laws and regulations

• General Data Protection Regulation
• General Data Protection Regulation Implementation Act
• Code of Civil Procedure
• Bailiffs Act
• Seizure-free-foot simplification law
• Decree on attachment free feet
• Administration Regulation of Bailiffs
• Regulation KBvG Standards of Quality (KBvG = Royal Professional Organization for
  Bailiffs)
• Regulation Digital Bailiff Register for Bailiffs.
• VISH covenant (VISH = Schuldhulpverlening Referral Index)
• General provisions citizen service number law
• Personal Records Act
• Guidelines Authority Personal Data Security.
• Policy rules Personal Data Authority Identification and verification of personal data
• Personal Data Protection Authority Policy Rules.
• Beleidsregels Autoriteit Persoonsgegevens Meldplicht Datalekken (Data Breach Notification Duty) Policy Rules.
• Policy Rules Personal Data Authority Camera Surveillance.

Our contact details
Bosveld Bailiffs & Collections B.V. Databankweg 26-30, 3821 AL Amersfoort
Tel: 033-4700000

2. Who we collect data from
We collect and use data from the debtor. That is you or you and your partner
if there is joint debt. If you are represented by another person,
for example a trustee, debt relief worker or lawyer, we also collect
from this person a limited number of (contact) details. In the case of a minor with a debt, we also collect and use the data of the parent(s) or guardian.

3. Why we collect data
You have an outstanding debt according to our client. The principal has asked us to collect the debt. We therefore seek contact with you and need your contact information to do so. If we have to summon you to appear in court in a second step,
we have a legal obligation to request information about your official residence. And we need to be able to assess whether a lawsuit makes sense. To do this, we look at whether there is a special debt situation.

When seizing your income or assets, we need to know which they are
and whether they may already be attached. When placing an attachment on your income, the judicial officer is required to check whether it has already been attached and must determine the attachment-free amount.

4. Data collected by us.

4.1. Data provided by the client

The company, person or organization that is still owed money by you has -sometimes through an intermediary (for example, a collection agency or a lawyer)- instructed us to approach you. We receive from this creditor or his intermediary your contact details, information about the outstanding invoice(s) and the amount involved.

4.2. Information provided to us by you

There is information you give to us in emails, letters, phone calls, conversations at
the door or at our front desk. We use this information if it is relevant to
collecting your debt. If you have corrections to an attachment-free foot established by us, you can communicate them to us. To do so, you will then provide additional information, which we will use to recalculate the attachment-free foot.

Special data

We never ask for special personal data such as information about your ethnicity, religion or health. You may give us special personal data without us asking for it. In that case, we do not store or use it.

Your statement of income and expenses

It may be possible that when you apply for a payment plan that we will ask you to complete and submit to us an income and expense form. This form can be downloaded from our website. We use the information you put on this form
to determine the weekly or monthly amount you need to pay us to pay off the debt.

Recording phone calls

If we call you, we can record the phone conversation. We can listen back to the phone calls. We do this to train our staff and for quality purposes. The recorded phone calls are deleted after 90 days.

4.3. Data we collect ourselves

The judicial officer may use special data sources. This is allowed if he is preparing a lawsuit or if he has a judgment against you.

Data when preparing a lawsuit

The judicial officer checks your address information in the “basic registration of persons.

That way he is sure to deliver official documents for litigation to your proper address. The bailiff also looks in the “digital attachment register. This contains information if your salary or benefits have already been garnished. The judicial officer sees the type of attachment that has been made, the amount for which the attachment has been made and the name of the judicial officer who made that attachment.

Data if a judgment is present

The judicial officer can check your address information in the “basic registration of persons. He must do this if he has to deliver official documents to your address. In this way he ensures that he always does so to the correct address.

The judicial officer can retrieve your citizen service number from the data source ‘UWVpolis’. With this, the bailiff can request an overview of your employers over the last few years. He can also see whether you receive any benefits (from the UWV).

We may ask your employer for information about your salary.

To the IRS, we may ask for information about surcharges you receive from the IRS.

The judicial officer can also view the register “Rijksdienst voor het Wegverkeer” (hereinafter referred to as “RDW register”) and see if there is a vehicle in his name. He gets from the RDW register the registration number and data on make, type and color of the vehicle and in whose name the vehicle is registered.

Data for calculating your attachment-free foot

The bailiff uses a mandatory calculation module to calculate the attachment-free foot. The calculation module uses your citizen service number and retrieves your income data from the UWV. We then process, among other things, your address details, living situation (e.g. married), income details and the determined attachment-free amount.

Data from a home visit

As part of our work, we may also visit your address, such as to leave an official document (for example, a subpoena). We then note details about the type of property and classify the residential area.

Other data we may collect

As part of our work, we may also consult the following sources:

• Debt Assistance Referral Index
  This registry (which is fed by municipalities) shows whether you are known to be receiving possible counseling from a debt assistance provider. We are then shown the name of the debt relief provider or agency. Not all municipalities are connected to this.
• Central Curatorship and Guardianship Register and Insolvency Register
  This register shows whether you are under guardianship or guardianship. We will see the name and contact information of the debt relief provider or agency.
• Other bailiffs

We may approach other bailiffs in your area to ask if they also have claims pending against you, or if they have levied attachments against you. We can do this to file for your bankruptcy, for example, or to determine whether it makes sense to file a particular attachment.

• Chamber of Commerce
  We can check the Commercial Register to see if you have a company in your name, or if you may be registered as a shareholder.
• Central Register of Wills
  We can consult this register if the debtor has died to see if there may be heirs to pay the debt.
• Administrator
  We may get in touch with your administrator to obtain information about the administration.
• Debt counselor
  We may contact your debt counselor to obtain information about your debt position.
• Authorized Representative
  We may contact your authorized representative to make arrangements for paying off the debt or to communicate about the debt itself.

4.4. Customer Satisfaction Survey
If you have contacted us by phone we will send you a customer satisfaction survey that day (if known to us) via email asking you to enter it.

The customer satisfaction survey is solely intended to further improve our services. We only collect your answers and this is anonomized by default (We do not link your answers to your email address). In the survey we may ask you if we can contact you at a later time. In this case we do link your email address to your answers so that we can contact you.

5. Why we may collect and use your data
There is a party who has provided you with a service, sold you a product, to whom you must pay a fee or, for example, a fine. We call that party “the creditor. The creditor may be our direct principal. The creditor may also first engage another party to collect its claim, for example a collection agency or a lawyer. We call that party ‘the intermediary’.

When collecting an outstanding debt, the judicial officer always works on
behalf of another person (the principal). A principal can therefore be an intermediary or the creditor himself.

The principal or creditor believes that you still owe them money. We may collect and use information from you because you have yet to pay an amount to the principal or creditor. This may be because you have yet to fulfill an agreement or because you have a legal obligation to fulfill.

When preparing for a court case and in our work as judicial officers (the “official” work), we are required by law to check your address in the Basic Registration of Persons.
If you fail to pay, the judicial officer may see if he can attach your income or property. To do so, he consults various registers and uses this information. This use is covered by the judicial officer’s legitimate interest in carrying out his work.

6. Who we share data with.

6.1. What we share with our client

We have a lot of contact with the client in our work. We give the creditor information about payments you have already made to us, about payment arrangements we agree with you, and if you object to the debt, for example. We also give the principal information about a contact moment with you, for example, the date and type of a letter sent to you or of a telephone conversation.

6.2. Transfer of data to another judicial officer

We sometimes share your information with other bailiff offices in the Netherlands. For example, if you live in an area where we do not work regularly and we still want to get in touch with you. The data we share are address details, details of a summons or subpoena or details of a judgment or attachment. The fellow judicial officer is subject to the same laws and regulations. And the colleague is fully responsible for processing your data. If you have questions about your data, you can then contact us or our colleague.

6.3. Digital attachment register

If we, as judicial officers, seize your income, we must record in the digital seizure register who the seizure is made against, the type of seizure and the amount for which we are seizing. The digital attachment register is the responsibility of the Royal Association of Bailiffs (the KBvG).

6.4. Moving company and locksmith

In an eviction, we use a locksmith and a moving company. We give the locksmith and moving company only the date of the eviction and the home address.

6.5. Sharing your data outside the Netherlands

If there is a foreign client, we share information with that client. If you are in another country, we engage a party in that country to collect the debt on our behalf. We then share with that party the information needed to perform the assignment.

All European countries, Liechtenstein, Norway and Iceland (the European Economic Area) are subject to the same legislation when it comes to personal data protection. If we share data outside the European Economic Area, we first assess the situation about the protection of personal data in that country. We then register
what data we share.

6.6. Transmission of data

Passing on information about your garnishment-free foot to another garnisher
If another garnisher (for example, the tax authorities or UWV) levies a garnishment, they can request your garnishment-free foot from us.

7. How we protect your data

We take appropriate security measures to protect your data. In doing so, we pay particular attention to ensuring that your data does not end up with others and that no one has unauthorized access to our building, our systems and your data. We have our security measures checked regularly.

We work with parties that meet the strictest standards for information security. They are periodically assessed for compliance with those rules by an external party. We regularly verify that those parties continue to meet those standards.

8. Automated processing of personal data

Bailiffs have an obligation to ensure that they do not incur unnecessary expenses. This applies to those who have yet to pay a debt, but also to our clients. In order to ensure this, Bosveld employees make careful decisions on a daily basis.

If we have a new case pending against you, we look to see if we have had a claim against you before. If that is the case, we will use your existing information to assess whether it makes sense for us to handle the new claim against you.

When we get a new case on you, we may also compare certain information about you to a weighted average from our database. We then look at age, the amount of the claim and the amount of contact information present. This allows us to estimate how likely it is that we will collect the claim from you. We can use the outcome to see which treatment path is the best fit so that we do not incur unnecessary costs and are expected to get the claim paid the fastest.

9. How long we keep your data

We do not keep your data longer than necessary. In connection with a legal retention obligation, we keep your data for 10 years in almost all cases.

10. What rights you have

The personal data is data about you. We think it is normal that you are allowed to
know exactly what data we have about you (right of access). If there are errors in the data
you may ask us to correct it (right of correction). You may also ask that we no longer
use data about you (objection to processing) or even delete data about
you (right to erasure of data). These requests about your data can
you can make at privacy@bosveld.nl or you can contact our data protection officer.

Inspection rights

You may ask us exactly what data about you we have. You can ask this question at privacy@bosveld.nl. We will then send you a form and ask you to complete and sign it. Upon receipt of the fully completed and signed form,
you will receive a response from us within 4 weeks. In principle, this response will include an overview of all the personal data we have on you, unless we need more data from you or cannot fulfill your request. We will explain this in our response.

Right of correction

It is important that your data is correct. You may ask us to correct or supplement your personal data. This is possible if these data contain errors or are incomplete.

You can make a correction at privacy@bosveld.nl. After our own review, we can make these changes immediately. We may also send you a form and ask you to complete and sign it. Upon receipt of the fully completed and signed form, you will receive a response from us within 4 weeks that we have made the correction, unless we need more information from you or cannot fulfill your request. We will then explain this in our response.

Objecting to the use of your data

You can ask us to stop using your data. We will always review this request carefully but often have the authority to continue using your data. Please contact our data protection officer if you wish to object to the use of your data, or send an e-mail to privacy@bosveld.nl.

Right to erasure of data

You may ask us to delete your data. In most situations, we have a
legal obligation to keep data for a number of years. In that case
we may not delete that data. We will always review your request carefully
and let you know if we can delete data about you. If we cannot, we will give
the reason why. Please contact our data protection officer if you want to have data of yours deleted, or send an e-mail to privacy@bosveld.nl.

11. How to file a complaint

If we collect data from you and you are dissatisfied with this privacy statement or the way we handle your data, you can file a complaint with the Dutch regulator: the Authority Persoonsgegevens.

Contact details Authority for Personal Data
Visiting address: Bezuidenhoutseweg 30 / 2594 AV The Hague (by appointment only)
Postal address: P.O. Box 93374 / 2509 AJ The Hague
Telephone number: 0900 200 12 01 (usual telephone charges)

12. Modification of this privacy statement.

We ensure that this privacy statement is current. We update this statement if we collect new or different data, provide it to new parties, or there are changes in retention periods or security measures

For an overview of suppliers with whom we share your data, please click on this link. Here you will find an overview of Bosveld’s processors and sub-processors.