Privacy at Humaniversity
Why do we ask for your information?
In the application form we ask you for your name, contact details, gender, birthdate, nationality, personal status (single, married, etc), education, profession, emergency contact details, previous experience, motivation and medical information.
We need your contact details in order to process your booking and payments.
We need the rest of the information in order to determine if the program is suitable for you, and to care for you in the best way possible while you are here. We want to ensure that the program will benefit you, and not conflict with other treatments you are having or have had in the past. We also want to ensure that while you are here, you stay within your physical limits.
During your stay we may ask you for personal written information such as life stories and evaluation forms. To keep track of your progress during your program and to guide you in the best direction, we will also take notes describing your clinical process. At times, we may also make audio or video recordings as part of the group process. All of this information will be kept confidential and secure.
We need to have a legal basis in order to collect, process and store your information.
Our legal basis is to fulfill a contract with you as a participant in our program. Because of the therapeutic nature of our work, we also need medical and clinical information about you. For this sensitive data we must ask you for consent.
How do we handle your information?
The only people who have access to it are our Booking Office staff and the teachers and their assistants. They have all signed confidentiality agreements and been trained in procedures to maintain the confidentiality of the information.
How long do we keep your information?
We keep your information, including any correspondence you have sent us, for 10 years after your last visit, so that when you come back to us in the future, we have a record of what you have done, and we can help you to pick up where you left off. After 10 years since your last visit, we will erase all of your clinical information (see exception for WGBO data below), including your application form and emails, and keep only your name, contact details, gender, birthdate, and a record of your attendance and graduations. This information is kept in perpetuity for our academic records.
As required by Dutch law regarding medical care (WGBO), clinical information from sessions performed by a psychosocial or alternative medicine therapist will be kept for 20 years.
As required by the Dutch tax authority, we keep your invoices for 7 years.
Email Newsletter and Postal Sendouts
Only with your consent are you added to our electronic and postal mailing lists. This consent is given by signing up on our website, ticking a box on your application form or asking to be subscribed by some other means.
We never share our email lists with any outside source unless it is a joint event with Humaniversity. We respect your privacy and want to make it as convenient as possible to unsubscribe from our email list. You can do so via our website newsletter subscription/unsubscription page or by contacting the booking office. To change your preference for postal sendouts, please contact the booking office.
Photos and Videos
We ask for your explicit consent to use photos and videos that you appear in for promotional purposes. The photos and videos are saved in our media archive in perpetuity and handled respectfully and with discretion by our staff.
Security Camera Recordings
We have a legitimate interest to provide a safe environment for participants and staff on the Humaniversity campus. In order to accomplish this, we have security cameras monitoring the entrance and the areas surrounding the buildings. The recorded video is saved for four weeks on our secure computer system and then deleted. In the case of a security incident, we may save relevant clips of the footage until the incident is resolved. You have a right to object to being recorded by our security cameras. We will consider your objection seriously. However, we will need to weigh your request against our responsibility to keep the people and property of the Humaniversity secure.
Right to withdraw consent and right to erasure
You always have the right to withdraw your consent to appear in photos or videos used for promotion at any time. We will then erase your images or video, except in rare cases where the effort involved would be infeasible.
Regarding the consent you have given us to keep your medical and clinical data, we have an agreement and therefore a legal obligation to the CRKBO (Centraal Register Kort Beroepsonderwijs) Netherlands, our registering body, to keep this information as part of our participant records for 10 years. After that time, a request to erase this information will be fulfilled.
Right of access – We must provide your data to you if you request it.
Right to rectification – You have the right to rectify inaccurate or incomplete data
Right to data portability – You also have the right to receive your data in a common, machine-readable format.
Time Frame and Fee:
All of the above requests must be fulfilled without a fee and without undue delay, latest within one month. If the request is complex or numerous, we can take an additional 2 months to complete the request, but the extension and reasons for it must be explained to you.
If any of the above requests are excessive, repetitive or unfounded, we are permitted to charge reasonable fee or refuse the request.
If we refuse a request, we will inform you of:
- our reasons for refusal,
- your right to make a complaint to the Autoriteit Persoonsgegevens within one month, and your ability to seek to enforce this right through a judicial remedy within one month.
Right to make a complaint:
If you feel we are not handling your data correctly, please contact our Data Protection Officer
You also have the right to make a complaint to the Autoriteit Persoonsgegevens.
If you have any questions about privacy at Humaniversity, please contact our Data Protection Officer.
This policy was updated on May 15, 2018
Dr Wiardi Beckmanlaan 4
Egmond aan Zee 1931BW
Tel: +31 (0)72 506 4114