privacy statement

January 2022

why this privacy statement?

If you work for hamilton bright or one of its subsidiaries (collectively hamilton bright group), or apply for a job with us, or visit our website out of interest, or make use of our app or respond to our social media posts, we need some of your personal data. Because we want to be transparent about how hamilton bright group processes your data, we have published this privacy statement.

Hamilton bright group is committed to treating your personal data ethically and with care. We process and secure your data in compliance with the General Data Protection Regulation (GDPR).

We have summarised the personal data we process, why we do so and how we handle your personal data below. We also explain how you – as a client, employee, former employee, job applicant or visitor to our website – can exercise your rights to, for example, view your data or have it deleted.

personal data that we process

Hamilton bright group processes your personal data because you make use of our services and/or because you have supplied this data yourself.

You will find a summary of the personal data that we process below:

  • forename and surname
  • gender
  • date of birth
  • place of birth
  • address details
  • telephone number
  • e-mail address
  • bank account number
  • IP address
  • data about your activities on our website
  • data about your surfing behaviour across various websites
  • location details (SmartSpotter)

sensitive and/or special personal details that we process

Hamilton bright group processes the following sensitive and/or special personal data about you:

  • social security number (Burgerservicenummer, BSN)
  • data about persons under the age of 16

Our website and/or service is not intended to collect data about website visitors under the age of 16, unless they have the permission of their parents or guardian. However, we cannot verify whether a visitor is over the age of 16. We therefore advise parents to be aware of their children’s online activities, to ensure that data about children is not collected without parental permission. If you believe that we have collected personal data about an underage person without such permission, please contact us using this web form and we will delete this information.

the purpose of processing personal data

Hamilton bright group processes your personal data for the following purposes:


Hamilton bright group collects and processes employees’ data for the purpose of maintaining a complete, accurate and effective personnel administration system, while taking account of the requirements of the Dutch Tax and Customs Administration (Belastingdienst), accountants and legislation. In addition, hamilton bright group uses employee data to implement elements of our personnel policy, such as the retention and motivation of staff, communicating information about company developments and the use of resources for the development of staff, including Unit4 Talent Management software.

job applicants

In respect of the collection of the personal data of job applicants, hamilton bright group aims to compile and maintain an effective talent pool to fill vacancies that may arise now or in the future.


Hamilton bright group also processes the data of former employees, who are added to hamilton bright legends if they have granted permission for this. The purpose of processing this data is to maintain a network of these former employees, to inform them about developments at hamilton bright group and to communicate with them about activities organised for and with them, etc.

website visitors

To this end, we analyse surfing behaviour on the website. This allows us to obtain a clear picture of where we can optimise the website. We can see the surfing behaviour of our website visitors, but not who actually visits the website. Your data is always anonymous with us. Hotjar is installed on our website as a cookie to measure this surfing behaviour.


Via the SmartSpotter app, users’ location data is stored to detect fraud. The terms and conditions for the use of the app, and how this location data is handled, is specified in the SmartSpotter privacy statement.

how long we retain personal data

Hamilton bright group is obliged to retain certain personal data for five years after an employee leaves the company:

  • the income tax declaration.
  • a copy of the employee’s proof of identification.

There is no statutory retention period for the rest of the data in the personnel file. Hamilton bright group retains this data for two years after an employee leaves the company.

If this data concerns a job application, hamilton bright group will request permission to retain this data if this is relevant for later opportunities. If this permission is granted, the retention period is one year, after which permission will be sought again if relevant. If the applicant does not grant permission, the retention period for the data is four weeks.

Once this period has expired, or if the data is no longer needed, Hamilton bright group will ensure that all papers and digital data are destroyed with care.

sharing of personal data with third parties

Hamilton bright group does not sell your personal data to third parties, and will only provide this data to others if this is necessary for the implementation of our agreement with you, or to comply with a statutory obligation. We will conclude a data processing agreement with any companies that process your data on our behalf to ensure that the same level of security and confidentiality is guaranteed. Hamilton bright group remains responsible for this processing.

how we protect personal data

Hamilton bright group takes the protection of your personal data seriously and will undertake appropriate measures to prevent misuse, loss, unauthorised access, undesired publication and unauthorised changes. If you nevertheless believe that your data is not properly secured or if there is evidence of misuse, please contact

viewing, altering and deleting data

You have the right to view your personal data and to have it corrected or deleted.

In addition, you have the right to withdraw any permission you may have granted for your data to be processed, or to object to the processing of your personal data by hamilton bright group. You also have the right to have your data transferred. This means that you may ask us to send a copy of the personal data that we have on you in a computer file to you, or to an organisation specified by you.

You may send any request to view your personal data or have it corrected, deleted or transferred, or a request to withdraw your permission or an objection to the processing of your personal data, using this web form.

To verify that the request to view your personal data came from you, we ask you to send a copy of your proof of identification with your request. On this copy, obscure your passport photo, MRZ (Machine Readable Zone, the strip with numbers at the bottom of the passport), passport number and social security number (burgerservicenummer, BSN). This is to protect your privacy. We will respond as soon as possible to your request, and within four weeks at the latest.

cookies, or comparable technology, that we use

Hamilton bright group only uses technical and functional cookies, and analytical cookies that do not affect your privacy. A cookie is a small text file that is stored on your computer, tablet or smartphone the first time you visit the site. The cookies we use are necessary for the technical operation of the website and your ease of use. They ensure that the website works properly and store your preferences, etc. They also allow us to optimise our website. You can opt out of cookies by setting up your internet browser so that it no longer stores them. You can also delete all data that has previously been stored via your browser settings.

Your right to submit a complaint to the supervisory body

If you disagree with how we treat your personal data and are not satisfied with our response, you may submit a privacy complaint to the Dutch Data Protection Authority (Autoriteit Persoonsgegevens, AP) by:

  • contacting the AP’s Information Point and Hotline: telephone: +31 (0)88-1805250, open from Monday to Friday from 10:00 to 12:00.
  • submitting a complaint using the reporting form on the Dutch Data Protection Authority’s website.
  • sending a letter to:
    Autoriteit Persoonsgegevens
    Postbus 93374
    2509 AJ Den Haag

when changes are made

Hamilton bright group reserves the right to modify this privacy statement from time to time. We therefore advise you to regularly check this privacy statement for the most recent update.

If you have any questions about this privacy statement, please do not hesitate to contact us. You can send any questions and/or remarks to:

Please send all requests and questions related to the GDPR and your personal data using the web form here.

Our privacy statement was amended on 4 January 2022.