Privacy statement

Introduction

This is the privacy statement of Strukton Groep B.V. and its operating companies (hereinafter referred to as ‘Strukton’ or ‘we’). Our registered offices are at Westkanaaldijk 2, 3542 DA Utrecht, the Netherlands. This privacy statement applies to each of the aforementioned entities. Each entity is individually responsible for the data processing referred to in this statement, in as far as not provided otherwise in this statement. The individual entities do not have access to each other’s data.

In order to be able to perform our activities  properly, it is sometimes necessary to process your personal data. We always do this with care and in compliance with laws and regulations in the field of protection of personal data. This privacy statement explains which data are processed, what we process your data for and what your rights are.

The privacy statement may be changed from time to time. We inform you of any changes before they come into force.

Processed data, purpose of and grounds for processing

Personal data are all data that provide information on an identified or identifiable natural person. A natural person who can be identified directly or indirectly is regarded as identifiable. We use the data that we gather for the purposes and on the basis of the statutory grounds described below.

Visiting our website

If you visit our website, we will process data, independently or jointly, including your IP address and data on your activities on our website, such as your clicking behaviour, internet browser and device type. We do this partly by means of cookies. More information on the operation of cookies, the purposes for which we use them and how you can withdraw consent for the cookies placed is available under ‘Cookies’. We use the above data:

• to analyse how visitors use this website; and
• to coordinate the content of this website and advertisements on this website, social media or third-party websites with your interests (profiling). We do not link these data to your name, address, email address and the like, if we know these.

Applying for jobs at Strukton

If you apply for a job via our website, we ask you to provide the necessary information, such as your name, address, phone number, e-mail address, date of birth, and CV. We process these data, possibly supplemented with a cover letter, references, certificates, notes, assessments, and any e-mail correspondence.   Your data are used only for the performance of the recruitment and selection procedure within Strukton and to assess the suitability of the applicant for a specific vacancy.

Strukton processes this personal data based on the preparation of the execution of a (potential employment) agreement with you. On the grounds of reasons relating to your specific situation, you have the right at all times to object to this processing (see ‘Your rights’ below).

Recording of train tracks via inspection train

For track maintenance purposes, Strukton uses, among other things, the Leonardo Inspection Train. This train is equipped with cameras, lasers, and radar to inspect and digitally map the railway infrastructure and surroundings. During this process, individuals or license plates may be incidentally captured on camera.

The basis for the processing of these personal data is the legitimate interest of Strukton, namely the preparation and execution of railway work, damage prevention, and technical documentation of the tracks. We have carefully weighed the interests: the processing is necessary for our operational tasks. The images are mainly used internally within Strukton and are not intended to identify individuals.

Occasionally, the camera footage is shared with our clients. In those cases, faces and license plates are automatically blurred before being provided to these clients.

Based on your specific situation, you may object to this processing at any time (see ‘Your rights’ below).

Data retention period

Strukton does not save your personal data for longer than is necessary. The term for which your personal data are saved depends on the purposes for which these data are processed and on the applicable statutory term for saving data. Strukton does not keep the data that you have provided for your job application any longer than is necessary, unless you have given permission for these data to be kept for longer.

Third parties

For the above purposes, we use supporting or additional services of third parties, such as IT suppliers and suppliers of recruitment systems. We contract processor’s agreements with companies that process your data on our instructions, which oblige them to protect your personal data adequately and to process these only in accordance with our instructions. Strukton remains responsible for this processing. Strukton does not provide your personal data to third parties. We do this only with your explicit consent. Strukton does not sell your data to third parties for marketing, sales or other business activities.

Security

Strukton treats the processing of your data with the greatest possible care. We continually take appropriate technical and organisational measures to protect your data against abuse, loss, unauthorised use, unwanted disclosure and unauthorised changes. This takes place partly through the IT security policy and by making use of secure storage and connections. These measures comply with the current statutory requirements and guidelines.

Your rights

You can exercise all rights that accrue to you under the current privacy legislation, including (A) viewing your data, (B) rectifying your data, (C) erasing your data, (D) restricting processing of your data, (E) the right to data portability and (F) the right to object to processing, by contacting us (see ‘Contact’ below).

(A) Right to access
You may ask us whether we process your personal data. If this is the case, you can access these data in the form of a copy.

(B) Right to rectification
You have the right to rectify your personal data if these are incorrect or incomplete. We will correct inaccurate personal data and supplement incomplete personal data on request.

(C) Right to be forgotten
You have the right to arrange for erasure of your personal data. This means that we will then delete your data. Your personal data will only be erased in certain cases that are prescribed by law and are listed in Article 17 of the General Data Protection Regulation (GDPR), such as when your personal data are no longer necessary for the purposes for which they were originally processed or when they have been processed unlawfully.

(D) Right to restrict data processing
You have the right to arrange for restriction of the processing of your personal data. This means that we will suspend processing of your data for a particular period of time. Circumstances that can give rise to this include situations in which the accuracy of your personal data is contested, but we need some time in order to verify their accuracy or inaccuracy. This right does not mean that we cannot continue to save your personal data. We will let you know when the restriction is lifted.

(E) Right to data portability
Your right to data portability means that you may request that you receive your personal data in a structured, customary and machine-readable form, if this is technically possible, and can transfer these to another party responsible for processing. On request, and if this is technically possible, we will then transfer your personal data directly to the other party responsible for processing.

(F) Right to object
You have the right to object to the processing of your personal data. This means that you can request that we do not process your personal data any longer. This applies only if ‘justified interests’ constitute the legal grounds for the processing (see ‘Processed data, purpose of and grounds for processing’ above). If you exercise this right, we will no longer process your personal data for these purposes.

Withdrawal of consent

You also have the right to withdraw any consent for the processing of your data, for example if you have given us permission to keep your job application data for longer and nevertheless wish to withdraw this at a later date. You may contact us for that purpose (see ‘Contact’ below). More information on withdrawing your consent for cookies and similar technologies that we use when you visit our websites is available under ‘Cookies’.

Questions, comments or complaints

If you have any questions, comments or complaints about this privacy statement, please feel free to contact us (see ‘Contact’ below). If your problem is not solved to your satisfaction, you have the right to submit a complaint to the competent supervisory authority. In the Netherlands, this is the Dutch Data Protection Authority (DPA). This can be done via this link.

Contact

If you wish to exercise your rights or have questions, comments or complaints about this privacy statement, you can send us a message at privacy@strukton.com.

If you wish to contact the Group compliance officer or a compliance officer of a specific entity, please check this page for their contact details.

In order to verify that the request to exercise your rights was actually made by you, we may ask you to provide additional information necessary to confirm your identity. We will respond to your request as soon as possible, and you will in any event receive an initial response within four weeks.