Privacy Investigation Services

Privacy Recerche Services
Van Kappel Security Solutions BV
Slope Street 22
1271VA Huizen

date: 14-06-2018
document version: 1/14-06
pages: 4
privacy officer: Stephan van Kappel office +31(0)35-5233134
direct mobile +31(0)6-54250075

This privacy statement is prepared by Stephan van Kappel for Van Kappel Security Solutions BV (VKSS) and covers the data of our clients and investigated persons within the research section. The Investigation Section has service duties with the objective of providing our clients with information and evidence that benefits truth finding. This privacy statement tells you what data we store, what the reason for this may be and what we do to ensure your privacy as best as possible.

VKSS is a detective agency that conducts investigations on behalf of third parties, whereby the legislation relating to this is observed as strictly as possible. These investigations take place primarily in areas of investigation that primarily involve issues such as housing fraud, unauthorized absenteeism, embezzlement in employment, stalking and threats. The personal data collected for this purpose relate to persons directly related to an unlawful act, either as perpetrator or as victim or rightful claimant with only relevant facts and circumstances concerning those persons being investigated and recorded.

Data Protection Officer or Data Protection Officer
Stephan van Kappel refers to VKSS's Data Protection Officer/Data Protection Officer. Stephan van Kappel is VKSS's point of contact for questions about how VKSS processes data and can be reached at

Processing personal data
VKSS may process your personal data because you use our services. We may also process your personal data because we have obtained it as part of an investigation. In both cases, you, the right holder, should be given the opportunity to take note of this and, if necessary, make changes or object. VKSS recognizes the importance of this and will prioritize each request to this end.

Purpose and basis of data processing
VKSS processes personal data for the following purposes:
- Customer information for the purpose of contact information and billing;
- Conducting criminal investigations;
- Advising regarding fraud and security
- Legal proceedings and returns to the competent authority
VKSS processes personal data exclusively based on the bases stated in the General Data Protection Regulation (AVG). When your personal data is processed by VKSS, VKSS will ensure that you are informed about the applicable basis and what this may mean for you. This will inform you by default what data we have collected from you, why we have collected this data, with whom this data is shared and when the data will be deleted by us.

Retention periods
VKSS stores personal data no longer than strictly necessary to fulfill the research purposes for which the personal data are collected. This is always based on a plan of action which you, as an interested party, can access at any reasonable request. VKSS uses the following retention periods for the following personal data:

Customer data
No more than 2 years after execution of the assignment. Customer data may also be kept longer if the customer has indicated a desire to continue to be informed. Research data Minimum of 6 months and maximum of 3 years after execution of the assignment provided there is pending or impending litigation. Maximum 6 months after completion of file and possible outcome of legal proceedings.

Camera images office
In this, the legitimate interest, subsidiarity and proportionality principles are very important. VKSS's policy in this regard is carefully observed. The footage will be retained for up to 2 weeks unless there has been a serious incident such as burglary or vandalism in or around the office. Images relevant to the case of threats to our employees will also be retained. In such cases, the relevant images are retained for the shortest possible time until the images have achieved their retention purpose. The images kept from this perspective are accompanied by a note showing;
- what can be seen in the images, no more and no less
- why are these images kept
- who is responsible for this
- Who has access to the images
- To whom the images have been shown or transferred ( the competent authority)
- what was the reason for this
- A statement from the person who obtained the images
- the date on which the images will be destroyed

Browse data
Maximum 6 months

Application details
Maximum of 4 weeks without the applicant's consent. Maximum of 1 year with the applicant's consent.

Sharing personal data with third parties
VKSS is not entitled to resell or disclose information to third parties, nor to change it without the customer's consent, nor to use it for any purpose other than that underlying the acquisition of the information required in the study.

None of what you communicate to us in good faith will be disclosed to third parties or used in any way for such purposes as marketing, research, statistics or related purposes. An exception to this concerns a notification to the competent authority if this can prevent serious disruption of public order and safety or in acute life-threatening situations.

Should there be any of the above, you will immediately be informed of this by means of a written report which will include;
- To whom was the information provided
- at whose request
- what data has been provided
VKSS may, however, share data with its attorney for the purpose of representing VKSS's interests in legal proceedings. VKSS has a duty of professional secrecy and must also adhere to the privacy code of conduct as compiled by the Dutch Security Branch and declared as binding by the Ministry of Justice.

VKSS uses only technical, functional and analytical cookies that do not invade your privacy. A cookie is a small text file that is stored on your computer, phone or tablet when you first visit the website. The cookies ensure the technical operation of the website and the ease of use of the website. You can opt out of cookies by setting your Internet browser to stop storing cookies. In addition, you can also delete any information previously stored through your Internet browser settings.

Viewing, modifying or deleting data
From the AVG, you have certain rights, which you can exercise under given conditions. You have the right to ask VKSS if they have processed your personal data to then view, correct or have it deleted. You also have the right to withdraw any data processing consent you may have or to object to the processing of your personal data by VKSS. You can submit a request to send your personal data that VKSS has processed in a computer file to you or another organization named by you, this falls under the so-called right of data portability. You also have the option to restrict the processing of your personal data, to do this you can submit a request and send it to VKSS will assess whether your request will be honored based on the facts and the AVG. To ensure that the request for inspection was made by the applicant, VKSS asks that you send a copy of your ID with the request. In this copy, make your passport photo, MRZ, passport number and BSN unreadable. This is to protect your privacy. VKSS' response time regarding the above request is 4 weeks.

Complaint Procedure
VKSS has a complaints procedure, which can be found separately on the website under "complaints procedure". If you believe VKSS has made a mistake while performing its work, you may file a complaint. The director of VKSS will handle the complaint and respond according to the guidelines of stated complaint policy. If, after going through the grievance procedure, you believe that your complaint has not been satisfactorily addressed, you may appeal to the Dutch Security Industry Appeals Committee within 6 weeks of receiving the director's decision on your complaint.

If you believe VKSS is not acting in accordance with the Privacy Act, you have the right to file a complaint with the Personal Data Authority (AP).

Data breach detection
In the event of a serious data breach, VKSS will immediately notify the Personal Data Authority (AP). VKSS will immediately inform the Customer of the actual situation and take appropriate measures.

In conclusion
VKSS reserves its right to make changes to this privacy statement. It is recommended that you consult this privacy statement regularly so that you are aware of these changes.

Huizen, June 14, 2018
Mr. S.S. van Kappel Director Van Kappel Security Solutions BV