EHRI Data Policy
This database might contain Sensitive Personal Data which according to Dutch privacy law can be used for research purposes only (article 16 Dutch Data Protection Act 'Wet bescherming Persoonsgegevens').
Sensitive Personal Data is any data related to an identified or identifiable person related to a person's religion or belief, race, political opinion, health, sexual life, trade union membership and criminal record.
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. These personal data will be treated with care.
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. Certain of these data are required for statistical purposes and are anonymised. The use of individual personal data is restricted to the purpose for which they were collected and of which the provider thereof is aware (e.g. sending out a newsletter). Such data will not be communicated to third parties.
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 Western, Eastern and Northern Europe, the USA and Israel. These collection descriptions may concern personal data or sensitive personal data (e.g. data pertaining to religion or ethnic origin). 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 major data protection risk. As a consequence, access to the collection descriptions and all the other information on the research portal is open to users.
Under the Dutch Personal Data Protection act, sensitive personal data can only be used for research purposes. Responsibility for compliance with the Dutch Personal Data Protection act 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 Dutch Personal Data Protection Act - 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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On the EHRI portal (https://portal.ehri-project.eu/):
4. Complaints procedure
The party responsible for processing the personal data in the sense of the Dutch Personal Data Protection act is NIOD. Duly justified complaints should be sent to firstname.lastname@example.org or to NIOD's postal address (addressed to its Director).