Privacy Statement

1. Introduction

ActToGrow is owned by Robert Knoester and he fulfills the role of Data Protection Officer (DPO). Robert is active in the field of human resources, learning and development, talent management and organizational development. In all of these areas, Robert fulfills the role of management consultant, program developer, coach or trainer/facilitator. Robert adheres to the standards of Dutch Institute of Psychologists (NIP). He supports his clients so that they are better able to deal with organizational challenges, talent development matters and career development choices.

2. Registration of personal data

For projects involving individual employees (coaching, training, consultancy) it is often necessary to register personal data within a business context. This takes place in accordance with the General Regulation of the Dutch Personal Data Protection Act (AVG).

3.  Purpose

The purpose of this privacy statement is to inform you about the way ActToGrow deals with processing personal data while adhering to all relevant legal regulations. It provides guidance about yours rights and explains the consequences if ActToGrow cannot process your personal data.

4.  Data
At the start of a project, project or collaboration you or your client provides data to ActToGrow. Individual employees can also be the client when it comes to a private project (coaching, training). This concerns data such as: name, address, city, address and telephone number, gender, date of birth etc. These data are being processed in the administration of ActToGrow. During the process, notes about you may be taken in more detail, such as: educational background and certificates, relevant company information, organizational charts, information about your work and/or career situation, test results and analyzes. This information is needed to enable ActToGrow to carry out the best possible services to you.

5.  Legal bases
ActToGrow registers personal details of its clients in order to be able to carry out its professional services properly. In doing so, ActToGrow bases itself on the following legal principles:
I. Client consent: you provide written consent for the processing of special personal data, such as data about making reports about your career or work situation.
II. Relevant client data: the data that are being processed are necessary for the execution of an agreement. If ActToGrow has been assigned by an employer, then there is always a signed agreement in place. In individual cases, ActToGrow will sign an agreement with the individual client.
For all agreements, certain personal data and other client information is needed and will be recorded.
During the execution of the work, ActToGrow uses data to communicate with its clients, for example telephone numbers, email address or invoice information
III. Compliance with regulators: the data that are processed by ActToGrow are needed to be  compliance with a legal requirements. For example, if ActToGrow needs to submit data to an Accountant or Tax Officer or when processing your payment.
IV. Data for representation or a justified importance. For example: to invite clients for a customer satisfaction survey or to send clients a newsletter and/or product information.

6.  Data processing
ActToGrow processes client data in its administration as far as needed to optimally execute it services like coaching, training, consultancy activities and for the use of products and tools. This means that only Robert Knoester, in its role as your trainer/coach/advisor, may have access to and is allowed to process the personal data that have been provided by the client. Any secondary professional(s) working for ActToGrow PACT will be given access to personal data after your explicit consent and if this is necessary in order to be able to carry out the services properly and to guarantee continuity.

7.  Agreements about written documentation
Before starting a project, ActToGrow will inform you about the use of written agreements and reports: to whom will be reported, what data will be reported and for what purpose. For written reports, action plans or development plans about you to the client, you must give your written consent first and sign off before the information can be shared.

8.  Inability to process data
If ActToGrow cannot process your personal data, it will not be able to enter into an agreement with you or your employer. The information is needed to execute the agreement.

9.  Confidentiality obligation
ActToGrow commits to processing your personal data with the utmost care and confidentiality. Your personal data and details are confidential and ActToGrow adheres to the professional code of the NIP. This applies, for example, to the conversations held, as well as to the recorded information. ActToGrow guarantees that your information is not distributed or unnecessarily shared with others without your consent. Exceptions are:
– if a legal provision legally forces ActToGrow to do so;
– if ActToGrow needs to involves sub-processors ( for example a registered accountant or book-keeper) who have to deal with personal data. These sub-processors need to adhere to the same regulations as the principal processor. Your privacy is therefore always guaranteed.

10.  Data retention
Regarding data retention, ActToGrow adheres to the relevant governmental regulations and Tax Authorities. If companies keep stricter policies, these will be adhered to, unless not compliant with the before-mentioned. In principle, ActToGrow retains personal data 5 years after closing of the project. Financial (invoice) data will be retained for 10 years.

11.  Your rights
ActToGrow provides its clients the right to view, change or delete their personal data. At any time, a client can withdraw its consent to the processing of certain personal data.

12.  IT security
ActToGrow processes data only in environments that are IT secure and are subject to the most up-to-date IT security standards. ActToGrow takes the security of your data very seriously. ActToGrow takes appropriate measures to prevent misuse, loss, unauthorized access, unwanted disclosure and unauthorized changes.

13. Customer satisfaction

ActToGrow trusts that its Privacy Statement contributes to the satisfaction of its clients. However, if you have concerns or complaints, please immediately contact the DPO (Robert Knoester at so that the problem can be discussed and solved