Privacy policy

The pension fund reserves the right to amend this privacy policy. We recommend that you consult this privacy policy regularly. This privacy policy is dated 4 September 2020.

Stichting Pensioenfonds Flexsecurity (hereinafter referred to as the 'pension fund’) and its administrator AZL (jointly referred to below as 'we') need you to provide some personal data so that we can operate and administer your pension as well as possible. This data includes your home address, salary, marital status, and citizen service number (BSN).

We process, collect, use, and store your personal data. We do this in compliance with the General Data Protection Regulation (the ‘GDPR’). We explain below how we do this.

Privacy policy FAQ

  • Whose personal data do we process?

    We process the personal data of

    • all members (and others with entitlements) of the pension fund
    • all website visitors
    • anyone who contacts us

    From whom and how do we obtain personal data?

    • from you if, for example, you send us an e-mail, telephone us, complete a contact form, or visit the website;
    • from your employer, including your salary data. We obtain all information and personal data necessary for the correct operation and administration of your pension. Your personal data is placed in a secure environment via a secure connection
    • from government and semi-public sector bodies, such as the municipality where you live for your current address or the UWV (Employee Insurance Agency) if you are to any extent incapacitated for work.
  • What personal data do we process?

    We process at least the following information of all members of the pension fund:

    • name
    • home address
    • e-mail address
    • date of birth
    • sex
    • civil status: if you are married or in a registered partnership, we also process your partner’s personal data
    • financial information, such as your salary and accrued or payable pension
    • Citizen service number (BSN)
    • bank account number
    • telephone number.


    Where relevant, we also process:

    • data concerning incapacity for work, such as your incapacity percentage
    • data that you leave behind after visiting our website, such as your IP address or, depending on your cookie settings, anonymised statistical data on information requested by visitors to the website.
  • Why and on what basis do we process your personal data?

    We process your personal data so that we can operate and administer your pension as well as possible. To process your personal data, we need to conform to various principles, which are the following:

    • Statutory obligations. These are obligations imposed by, for example:
      • the Pensions Act (Pensioenwet)
      • the Equalisation of Pension Rights in the Event of a Divorce Act (Wet verevening pensioenrechten bij scheiding)
    • the performance of a contract. These are obligations imposed by, for example:
      • the pension contract (the agreement between you and your employer)
      • the administration contract (the agreement between your employer and the pension fund)
      • the pension scheme (the scheme that applies between you and the pension fund)

    We may also occasionally process your personal data on the basis of:

    • your consent
    • a legitimate interest (for example, if necessary for conducting daily business or the day-to-day management of the pension fund)
    • the performance/compliance with contractual and other obligations/agreements.
  • To whom do we pass on personal data?

    If necessary, we will pass on your personal data to various parties. Which parties we send your personal data to depends on the situation. This could be:

    • internal disclosure to employees of the pension fund and employees of its administrator, and the exchange of personal data between the pension fund and its administrator
    • to supervisory bodies such as De Nederlandsche Bank (DNB), the Dutch Authority for the Financial Markets (AFM), and the Dutch Data Protection Authority (AP)
    • the Dutch Tax and Customs Administration (Belastingdienst)
    • other governmental and semi-public sector bodies such as Statistics Netherlands (CBS) and the UWV
    • third parties that we engage to operate and administer your pension as well as possible.
  • Protection of your personal data

    Your personal data must be properly secured. This is something that we as your pension fund and the pension administrator take very seriously. We therefore take technical and organisational measures to protect your personal data. Examples include measures against crime and cybercrime, destruction, loss, or other unlawful processing. These measures at least comply with the general requirements applicable to data protection. We assess these measures at regular intervals and update them where necessary.

    We have also made agreements with both internal and external parties regarding the confidentiality and security of your personal data.

    Processing outside the European Union

    Only in exceptional circumstances may your personal data be processed by an organisation in a country outside the European Union. In cases where this is done, appropriate additional measures will be taken to ensure compliance with European standards for the protection of personal data under the General Data Protection Regulation.

  • Your rights

    The law gives you certain rights that you can exercise with regard to organisations that process your personal data:

    • the right of access by the data subject
    • the right to rectification
    • the right to erasure (also known as ‘the right to be forgotten’)
    • the right to restriction of processing
    • the right to data portability
    • the right to object

    You can make a request to exercise these rights. If you wish to do so, please contact us. You should send your request in writing, specifying the right or rights you wish to exercise. We will always respond.

    When can you exercise your rights? Two examples
    If you:

    • want to know what personal data we hold about you, you can exercise your right to access
    • feel that we have not correctly administered certain personal data, or that personal data needs to be rectified or supplemented, you can exercise your right to rectification.

    Filing a complaint

    You can file a complaint about the processing of your personal data. If you want to file a complaint, please contact us and submit your complaint in writing. We will always respond.

    Withdrawing consent

    If we process your personal data with your consent, you always have the right to withdraw your consent. You can do this in the same way as you gave it. In that case, we will stop processing your personal data as soon as possible.

  • Retention period for personal data

    We process your personal data to enable us to operate and administer your pension as well as possible. We will store your personal data for as long as we need it for that purpose.

    For an outgoing value transfer or the commutation of a small pension we retain your personal data for seven years after your retirement date (in our scheme).

    Furthermore, we comply with the statutory regulations governing retention periods. If we no longer need your personal data for the purpose for which it was collected, and there is no statutory retention period, we will cease to process it. We will then erase the personal data we have collected.

  • Cookies

    This website uses cookies. There are various types of cookies. Functional cookies are needed for the pension fund's website to function properly. We always send these cookies; they have no impact on your privacy. We only send cookies that do affect your privacy, such as analytical cookies, if you give your consent for this via the pension fund website the first time you visit. For more information, please see our cookie policy.

  • Contact

    Please feel free to contact us if you have any questions about how we process your personal data.

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