Privacy

Your privacy, our responsibility!

The protection of your privacy is important. We therefore handle your personal data very carefully and confidentially. We comply with privacy laws and regulations, such as the General Data Protection Regulation (AVG) and the Police Data Act (Wpg). We use your data only for the purpose for which it is needed and also do not keep it longer than necessary. We have also taken measures to properly secure your personal data.

What data do we use?

When you use services or products from the municipality, we need personal data from you. Personal data is data that contains information about a person and can be traced back to that person. Examples of personal data include:

• name
• gender
• date of birth
• birthplace
• address
• phone number
• email address
• Citizen Service Number (BSN).

Sometimes we also use special categories of personal data about you. This includes data about your health, religion, or criminal record. We are only allowed to do this if it is regulated by law.

What do we use your data for?

We register your personal data because we maintain the Personal Records Database (BRP) and because you use our products or services, such as:

• applying, for example, for a passport, a building permit or you if you want to use a wheelchair facility.
• performing our (public law) duties, such as reviewing your application.
• handling your payment.
• To call you when necessary for our services.
• Because we want to inform about changes to our services and products.
• If we are required to do so by law, for example, data we need for your tax assessment.
• certain investigative tasks performed by the special investigating officer, such as a traffic violation.

Find more information about keeping personal data confidential here.

We tell you!

Before we use your personal data, we will explain to you what we are using your personal data for, but most of the time this is clear to you. In some cases, we may even need to ask for your permission.

Sharing with others

In certain situations, our employees may ask you whether your data may be shared with, for example: (internal/external) colleagues or (government) agencies. You do not then have to tell another colleague everything again. Before we pass on your data to a colleague or authority in these situations, we will tell you this.

Public record of processing activities

The register contains information about what data we collect and process about you and why (Public Register of Processing Activities). You often provide this information yourself when you submit your application, but we also use your data from the Personal Records Database (BRP). Examples include applications for a passport, identity card, or driver's license. You can request the register of processing activities by sending an email to gemeente@aalten.nl.

The website www.wiekrijgtmijngegevens.nl lets you see which organizations receive data about you.

We enter into agreements with organizations that need your data on our behalf. We agree with these organizations that they will treat your data with the same care as we do. The municipality of Aalten remains responsible for the processing of your personal data.

You request something through our website

You can request more and more products and services through our website, your personal data that you provide when doing so are also covered by the AVG. If you fill out a contact or request form on our website, or send us an e-mail, the data you send us will be kept as long as the data are needed for answering and processing, or as long as it is legally required.

Save

We do not retain personal data longer than necessary or than required by law. We adhere to the statutory retention periods in this regard.

Security

We take the protection of your data seriously and take appropriate measures to prevent unauthorized access to, loss and misuse of personal data. These measures are contained in our information security policy. The way we should do this is in the Baseline Information Security Government (BIO).

Storage of data within the EU

We process your data within the EU. If for good reason we choose to store data outside the EU, we will use the same requirements for safety and security of your data. If we store data outside the EU, we will explicitly mention it in our public register of personal data processing operations.

Your rights

View, correct, delete, right of restriction or right of objection. You have the right to inspect and correct or delete your personal data. You can make a request online to see, correct or (where possible) delete your data. You can also make a written request. You can do this by filling out a form at the front desk in the municipal office. Would you like to know more about this? Then see our detailed information on your rights. For privacy reasons, it is not permitted to view data of other persons.

Right of limitation or right of objection

If there are special circumstances, you can object to any particular processing of your personal data or you can exercise your right to restrict processing. Do you think you qualify for this? If so, please contact the Privacy Coordinator at: (0543) 49 33 33. The Privacy Coordinator will work with you to see if you qualify to invoke these rights and, if so, explain the follow-up procedure.

Legitimate

You must provide proof of identity if you wish to view, correct, or delete your data. You can do this by submitting a digital request using DigiD on our website or by filling in a manual request form and presenting proof of identity at the counter in our municipal office at Hofstraat in Aalten.

Camera surveillance of municipal buildings

We have several buildings where camera surveillance is used. These are the town hall (Markt in Aalten), the municipal office (Hofstraat in Aalten), and the Eurohal (Europastraat in Dinxperlo). We have a camera surveillance protocol that specifies how we handle the camera images.

Use of bodycams

When bodycams are used, personal data are processed. When those involved are identifiable in the image, the General Data Protection Regulation (AVG) applies. The provisions of the Policy Rules on Camera Surveillance of the Personal Data Authority also apply. Below we indicate how and for what purpose the municipality processes these personal data. 

• Target 

The purpose of processing personal data through the use of bodycams is to increase the sense of security of special investigating officers (boas) and to reduce and possibly prevent incidents. The data will not be used in any way as a personnel tracking system (e.g., for assessment interviews). 

• Basis

The municipality processes these personal data on the basis of serving its legitimate interests as the employer of the boas. As an employer, the municipality has a particular responsibility for the safety and well-being of its employees in the performance of their assigned duties. 

• Storage

The municipality handles bodycam footage with care. The images are stored encrypted. If the bodycam is stolen, the images cannot be read and/or viewed. The bodycams are not connected to the Internet and are not linked to other applications. 

• Retention periods

It is an obligation to remove and destroy the images after 28 days based on the Archives Act, unless there is an incident involving the safety of a boa. In the case of an incident involving the safety of a boa, the images will be retained as long as necessary for the criminal and/or civil resolution of the incident. 

• Who may view the images

Only authorized officers of the municipality may view the recordings and only if it fits within the objective of increasing the safety of the officers. In addition, each data subject (the filmed citizen or enforcer) has the right to inspect their own personal data. All concerned can send a request for inspection according to the procedure mentioned on the Privacy/Bodycams page.

Facebook and Twitter

This website includes buttons to promote or share pages on social networks such as Facebook and Twitter. These buttons are realized by code provided by Facebook and Twitter themselves. Among other things, this code places a cookie (see above).

Please read the privacy statements of Facebook and of Twitter (which may change periodically) to see what they do with your personal data that they process using this code.

Complaints or suggestions about your privacy

We do everything we can to protect your privacy. Despite this, do you still have complaints about the way we handle your privacy or do you think things could be done better? If so, you can report your complaint or suggestion online below.

Report complaint or suggestion

Data protection officer (FG)

Mr. R. Brinkhof
E: fg@aalten.nl
T: 0314 37 73 77

Privacy Coordinator

Ms. A. Bruil
E: gemeente@aalten.nl
T: 0543 49 33 33

More information

If you have any questions after reading this information, please feel free to contact us. Our phone number is 0543 49 33 33.

This statement was last modified on 04-11-2025.

If a special investigating officer (boa) processes personal data as part of his police duties, the Police Data Act (Wpg) applies. Like the AVG, the Wpg sets requirements for the processing of personal data. With this we inform you about how we process police data.

The municipality employs special investigating officers (boas) for tasks related to supervision and enforcement of public order and social safety.  

A boa supervises public order and compliance with legal provisions. When violations occur, the boa supervises and takes enforcement action. To this end, a boa processes personal data. 

If a boa processes personal data in the performance of its supervisory task, the AVG (General Data Processing Regulation) applies. If a boa processes personal data as part of its police task (such as detecting criminal offenses and maintaining public order), the Police Data Act (Wpg) applies. Like the AVG, the Wpg sets requirements for the processing of personal data. The moment data are processed under the AVG, these data are called personal data. The moment personal data are processed under the Wpg, these data are called police data.

What do we process police data for?  

Under the Wpg, police data is processed for various purposes. These purposes are described in Articles 8, 9, and 13 of the Wpg. Examples include: writing a report when a criminal offense has been committed. Handling, administering, and financially settling payments related to the official report, such as granting objections, applying the leniency scheme (a scheme to resolve unreasonable adverse effects and distressing situations), applying reductions, and payment arrangements. Investigating and tracking down suspects of criminal offenses (including graffiti incidents).

What police data are processed?  

When giving notice of a lawsuit, we record:

• contact information
• birthplace
• date of birth
• description of the offense with day, date and time and location where the offense occurred
• citizen service number (BSN)
• type of ID
• identity card number
• financial information when paying a court order and/or making payment arrangements. 

When signaling offenders, locating criminal suspects and conducting investigations into crimes committed, we may also use camera footage.

What is the basis for processing?  

Police data cannot be processed just like that; a so-called processing basis is needed for that. The basis on which the boas process personal data for the Wpg is to carry out a legal obligation. The boas process personal data on the basis of: 

• Code of Criminal Procedure;
• Police Data Act;
• Extraordinary Investigating Officer Decree;
• General Administrative Order (APV). 

How long do we keep police records?  

The Wpg stipulates legally defined periods for how long police data may be retained. Once this period has expired, the personal data must be permanently deleted. Police data may be retained for a maximum of five years. After one year, the police data can no longer be viewed, unless there is a valid reason to review the police data again. We retain camera images of stations, stops, buildings, and grounds for a maximum of 28 days, provided there has been no incident. We store camera images that are used for the performance of police duties (such as images showing an incident or a crime being committed) in order to transfer them to the police for criminal proceedings. 

With whom will police data be shared?

Only authorized employees are granted access to the data. They may only view the data they need for their work. We may grant access to employees of the police or the municipality. They too are given access only to the data they need for their work. The actions of employees in systems are logged. We thus keep track of who performs what action at what time in a particular file. The recipients of the data are bound to secrecy. 

When issuing a report, we check the information in the Personal Records Database (BRP).

Sometimes it is necessary for the municipality to provide registered police data to third parties. For example, to the Central Judicial Collection Agency (CJIB) or to the Public Prosecutor's Office (OM) or the police because of an incident in which the municipality files a report. 

In addition, we sometimes share police data with processors who process police data on behalf of and for the municipality. These processors include collection agencies, cloud and hosting parties and IT service providers. A processor agreement is in place with these processors, setting out the mutual rights and obligations for processing. 

Your rights

Viewing police data

Under the Wpg, your rights differ from those under the AVG. You have the right to review the police data the municipality processes about you under the Wpg.

Modify, supplement or delete police records

If your police records are inaccurate or incomplete under the Wpg, you can ask the municipality to amend or supplement your police records. In addition, you can have police data deleted or request a restriction on the processing of your police data. 

You can submit your request to inspect, amend, supplement or delete police records digitally and log in with DigiD:

Police Data Act: Request for access to personal data 

You will receive notice from us when your request for access, correction, deletion or the restriction of the processing of your data has been processed.  

Legitimate

However, you must identify yourself if you want to view, correct or delete your data. This can be done by making the request via our website and logging in with DigiD.

Filing a complaint

Finally, you can file a complaint with the Personal Data Authority if you believe your personal data is being processed in violation of the Wpg. 

Reject request

We have the right to reject a request in the following cases:

• the request would impede judicial investigations or proceedings
• the request adversely affects the prevention of the commission of crimes, detection, investigation, prosecution or imposition of penalties
• public safety is at stake
• the rights and freedoms of third parties are violated
• national security is at stake  
• if the municipality has a legal obligation to retain this personal data the request is unfounded or excessive  

Privacy Act

Photos and images are personal data according to the new privacy law: the AVG (General Data Protection Regulation).

Why do we take photographs and image recordings?

As a municipality, we take pictures and video recordings about what is going on in our municipality and what we are doing as a municipality. For example, we organize various information, education, walk-in and other meetings on various topics and projects. We also attend fairs, markets, conferences, company visits, regional meetings and third-party meetings. As a municipality, we also take photos and image recordings of events in our municipality. You can also think of work we do in public spaces, presentation of royal awards or medals of honor, commemorations, openings and festive gatherings by a member of the college, as well as meetings of the City Council, the RTG and sometimes B&W.

We only use the photos and images for our own communications. This includes brochures, posters, the website, Facebook page, and Twitter. We do not share these photos and images with other organizations or companies.

When do we ask for your permission?

If you are the only person or one of only a few people in the picture, we will ask for your permission to use the photo or image. The photographer will give you a consent form from the municipality. On this consent form, you can indicate whether we may use the photo or image and on which channels we may publish it. For children under the age of 16, we ask the parents/legal representatives for permission. You are not obliged to give permission and you can withdraw your permission at any time. To do so, you can send a letter or email to gemeente@aalten.nl.  

When do we not ask for your consent

In some cases, we cannot ask permission from everyone personally. For example, there are many people in a photo or video recording. You may also be a passer-by in a photo or video recording. We always make it clear in advance that photographs or video recordings will be made. If you do not want to be in a photo or video recording, please let us know. Then we will take this into account. We handle your personal data as carefully as possible. We pay close attention to the subjects for which we use such photographs and video recordings.

Sometimes we make visual recordings

We do this to allow those who for some reason are unable to be physically present to still participate in this way. Again, if you do not want to be filmed, you can indicate this in advance. We will then take this into account.

Objection to a photograph or image capture

Have you given permission to use a photo that includes you, but want to withdraw the permission? Or do you object to a photo we have taken of you? Would you like us to remove a photo that you are in? Please contact us.

Municipality of Aalten
Attn: Privacy Coordinator
Postbus
7120 AC Aalten
Tel. 0543 49 33 33
gemeente@aalten.nl

Complaints

If you have a complaint or suggestion about the use of your photo, you can file a report online below. We will then work with you to see how we can resolve it.

Reporting a Complaint or Suggestion

The municipality of Aalten has a Data Protection Officer, Ms. A. Nas. If you have any complaints, you can also contact her by sending an email to gemeente@aalten.nl. If you are unable to resolve the issue with us, you can also submit a complaintto the national supervisory authority, the Dutch Data Protection Authority , at .

This statement was last amended on 20-08-2021.

Special investigating officers (boas) sometimes have to deal with unsafe situations, for example when people become aggressive. They then pose a threat to the boas and the people around them. That's why our boas wear a bodycam. This is a small portable camera on their uniform.

Working method of bodycams

• The boa only initiates recording in situations that are (threatening to) escalate.
• The bodycam is clearly visible and the boa always warns first and only then starts recording.
• The bodycam is always on standby.
• Does the enforcer press the record button? Then the bodycam also records the 120 seconds before that. In this way, the reason for the situation is also recorded.
• Is nothing going on and the enforcer does not use the record button? Then the image recordings are automatically overwritten (after 120 seconds). Then no images are saved.

Privacy and security of images

All images on the bodycam are properly secured. The images are unreadable and cannot be viewed or deleted by the on-site boa. After each shift, the images are stored on a secure server.

The recordings are automatically deleted after 28 days. Unless there is a reason to keep the recordings longer. The police and the Public Prosecutor's Office may request the images for criminal investigations. The boa itself may also request to see the footage again to learn from its own actions.

Right to view images

The municipality handles images securely. We adhere to the rules of privacy legislation (AVG). Have you yourself been filmed with a bodycam? Then you may come and see the recordings that were made of you.

You can request this in writing or by e-mail

• Municipality of Aalten
• Attn: Administrative Support and Security team
• P.O. Postbus
• 7120 AC Aalten
• Or by email: gemeente@aalten.nl

Please include the following information

1. Name, address, phone number and/or email address
2. The reason you want to view the images
3. Date, place, time the images were taken

More Information

If you would like to see the Protocol Bodycams please contact the municipality.

• Personal Data Authority
• Rijksoverheid Personal Records Rijksoverheid
• Information security service