In order to achieve some of its key objectives, it is necessary for EHRI to process personal data. EHRI complies with the General Data Protection Regulation (GDPR) and the Dutch Uitvoeringswet Algemene verordening gegevensbescherming (UAVG).
EHRI Data Policy
This database might contain special categories of Personal Data and Personal Data relating to criminal convictions or offences, which according to the UAVG can be used for research purposes only (article 24 and 32f) on the condition that there are appropriate safeguards for the rights and freedoms of the data subject.
Special categories of personal data in EHRI is any data related to an identified or identifiable person related to a person's religious or philosophical beliefs, racial or ethnic origin, political opinion, trade union membership, health, sex life or sexual orientation.
1. Data from users of this website and its services
In order to use a number of the features of the EHRI websites, EHRI requires certain personal data from you such as your name, address, email, and professional affiliation. This personal data will be treated with care and are safely stored.
For certain categories of website users, a set of personal data is kept, including pages consulted, address data for mailing lists and contact databases. This is necessary to enable the website to operate properly. Data required for statistical purposes and is anonymised. The use of individual personal data is restricted to the purposes for which they were collected and of which the provider thereof is aware and has given their consent (e.g. sending out a newsletter.) Such data will not be communicated to third parties or used for other purposes.
Users who register on the EHRI Portal and create a profile agree that the personal information they provide about themselves can be made available to other registered portal users and that their name will be published on the portal if they author public content. Registered users are contactable by other registered users and they may receive communications from such users to the email address provided. However, the email address of the recipient of such a communication will not be disclosed to the initiator of the contact. Registered users may further opt-out from being contactable by updating their profile preferences.
Except the cases listed above, EHRI will not pass on any data of registered users to third parties unless required to by law.
2. Data on the research portal
The research portal contains descriptions of Holocaust-related collections and sources kept in collection-holding institutions (archives, documentation centres...) in Europe, Asia, the USA, and Israel. These collection descriptions may concern personal data or special categories of personal data or personal data relating to criminal convictions or offences. Since the processing and publication of these data may have implications from the perspective of data protection, EHRI has conducted a risk assessment to determine whether these data can be accessed via the research portal and the internet. EHRI decided that, taking into account European and national personal data protection regulations, the nature of the collection descriptions, archival practice and the privacy policies of the collection-holding institutions, publishing these collection descriptions does not constitute a severe risk to the rights and the freedoms of data subjects. As a consequence, access to the collection descriptions and all the other information on the research portal is open to users.
Under the UAVG special categories of personal data and personal data relating to criminal convictions or offences, can only be processed if these data have been made public by the data subject, when the data subject has given their consent of for use for research purposes, if there are appropriate safeguards for the rights and freedoms of the data subject. Responsibility for compliance with the European and Dutch data protection legislation lies with the person ultimately publishing the data. Where research results are published in a country other than the Netherlands, the personal data protection act of that country must be complied with. Since the data on the research portal only involve descriptions of collections, a visit to the archive storing the records is necessary to actually access the documents. It is quite likely that this institution will have its own policy regarding access to the sources and privacy protection: this is explained in the detailed version of the country reports. Users have to comply with these specific procedures and cannot invoke the fact that they found a collection description on the EHRI research portal to gain access to the archived document itself.
If you consider you have well-founded grounds - based on the GDPR and the UAVG - against the publication of a specific set of personal data on the research portal, you may send a letter or an email, indicating your interest and explaining your reasons for objecting to publication, to the party responsible for processing the personal data. This party will examine your complaint and provide you with an answer within a reasonable space of time.
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4. Complaints procedure
The party responsible for processing the personal data in the sense of the GDPR is NIOD Institute for War, Holocaust and Genocide Studies, Amsterdam. Duly justified complaints should be sent to firstname.lastname@example.org or to NIOD's postal address (addressed to its Director):NIOD Institute for War, Holocaust and Genocide Studies
1016 CJ Amsterdam