Privacy Statement — Association of Swift Pensioners

The Association of Swift Pensioners — hereinafter “VG Swift” — values the protection of your personal data. This statement explains what data we process, for what purposes, who can see it, how long we keep it and what rights you have. We comply with the General Data Protection Regulation (GDPR).

1. Who are we?

The Association of Swift Pensioners (Vereniging Gepensioneerden Swift), established in the Netherlands and registered with the Dutch Chamber of Commerce under number 42152540. The board is the data controller.

Contact:

2. What data do we process?

We process only data that you provide to us yourself, and the data that arises from your use of the members’ platform.

When you register as a member (through the members’ platform at mijn.vg-swift.nl):

Personal details — name, address, e-mail address and date of birth; and, if you provide it, your telephone number.
Your time at Swift — whether you still work at Swift Netherlands, the years you worked at Swift, and the insurer(s) where you built up pension.
Your agreements — your acceptance of this privacy statement, the authorisation to interrupt the limitation period of any claim on Swift on your behalf, and your declaration that you filled everything in truthfully. For each agreement we keep the moment and the text you agreed to.
Membership — your membership number, whether you are an ordinary or associated member, the status of your membership, your language preference, and which board member approved your application.
Contribution — which contribution you have paid: amount, year and date. Your bank account number is not stored in the members’ platform; we only see it on our own bank statement.
Documents — documents you place in your own document archive yourself, such as pension statements.

When you use the members’ platform:

Logging in — your password (stored in unreadable form), and, if you use two-step verification, the associated key.
Session — while you are logged in: your IP address and type of browser. This disappears when you log out or the session expires.
Log — a security log of, among other things, failed login attempts (with the e-mail address that was tried), password changes, changes to two-step verification, and what board members do in the administration, such as approving applications, recording payments and downloading your documents.

If your registration does not go through:

Failed registration — if the form refuses something, or something goes wrong on our side, we keep your name, your e-mail address and what went wrong (which field, with the message you saw — not what you filled in), so that the board can contact you.

When you contact us in another way:

Content of your messages — the correspondence you have with us by e-mail or WhatsApp.
Telephone number — when you have asked to be added to our WhatsApp group.
Information shared voluntarily — for example about your pension situation, when you share it in the context of representing your interests.

We do not process special categories of personal data (such as health, religion or political opinions) unless you share them with us on your own initiative and give your explicit consent.

3. Why do we use your data?

Membership administration: assessing your application, keeping track of your membership and processing the contribution.
Representing the collective interests of pensioners, such as pursuing indexation of the insured pension.
Interrupting the limitation period of any claim on Swift on your behalf, so that it does not lapse (on the basis of your authorisation).
Keeping you informed of the association’s activities, in the members’ area and by e-mail.
Securing the members’ platform and being able to detect misuse.
Responding to your questions or requests, and adding you to the WhatsApp group if you have asked us to.

4. On what legal basis?

Performance of the agreement — your membership: the membership administration and the contribution.
Your consent — for the authorisation to interrupt the limitation period, for the WhatsApp group and for information you share with us voluntarily. You can withdraw your consent at any time.
Legitimate interest — in representing the shared interests of (former) employees of Swift, in securing the members’ platform, such as the log, and in contacting you if your registration does not go through.
Legal obligation — the association must keep its financial records.

5. How long do we retain your data?

We do not keep your data longer than necessary for the purpose for which it was collected. Specifically:

Member data: for the duration of the membership plus a maximum of two years afterwards for administrative settlement. The board then deletes it.
Rejected applications: until after the next general meeting, because you can still turn to the general meeting about a rejection (article 5(2) of the articles of association); after that we delete them.
Unfinished applications (e-mail address never confirmed): at most six months.
Failed registrations (name, e-mail address and what went wrong): at most 30 days.
Payment data in the accounts: seven years, as required by law.
Log: at most two years.
Session data (IP address, browser): until you log out or the session expires.
Correspondence: at most seven years when it has case value (for example in an ongoing legal matter), otherwise shorter.
Backups: the server makes a backup every night, which is overwritten after seven days. Our hosting partner also keeps its own backups of the server, for at most 90 days. And the board occasionally keeps an encrypted backup on its own computer, for at most three months.
Web server access logs (IP addresses of visitors): at our hosting partner, at most twelve months.

6. Who can see your data, and with whom do we share it?

Within the association only board members have access, each only to what belongs to their own task:

All board members see the member list and your member details, including your time at Swift, your insurers and your paid contribution.
Your own document archive is only for you and the board; every download by the board is recorded in the log.

Other members do not see your data.

Outside the association we do not provide your data to third parties for commercial purposes. We share it only in the following situations:

Lawyer or legal adviser — when this is necessary to represent members’ interests, for example to interrupt the limitation period of a claim on Swift on your behalf. We then share only the data needed for that. Before we share data of individual members with a lawyer or adviser, we let you know in advance.
Our hosting partner — mijn.host, with servers in Dutch data centres. It hosts the website, the members’ platform, the database, the backups and our e-mail. Mijn.host processes this data only on our instructions, under a data processing agreement, and uses suppliers of its own for this (for example for backups); these are listed at mijn.host/trust/subverwerkers.
Our bank — ABN AMRO receives your payment, with your name and account number.
Legal obligation — when we are legally required to.

When you are added to the WhatsApp group, your telephone number becomes visible to other group members. WhatsApp is operated by Meta; Meta’s privacy policy also applies to that use.

7. Security

We take appropriate technical and organisational measures to protect your data against loss or unauthorised access. Among other things:

All connections to the website and the members’ platform are encrypted (https).
Passwords are stored in unreadable form.
Documents in your archive are stored encrypted.
Board accounts can only log in with two-step verification.
Each board member only has access to what belongs to their task, and actions in the administration are recorded.
The server is located in the Netherlands and a backup is made every night.

8. Your rights

Much of this you can do yourself: on My details in the members’ platform you can view and change your personal details, your time at Swift and your insurers, and in your document archive you manage your own documents.

In addition, under the GDPR you have the following rights:

Access — to request which data we process about you.
Rectification — to have incorrect data corrected.
Erasure — to have your data deleted. Your data then also disappears from the members’ platform; it remains in the backups until these are overwritten or removed as described in section 5.
Restriction — to have processing temporarily suspended.
Portability — to receive your data in a common format.
Objection — to the processing of your data.
Withdrawal of consent — at any time, without giving a reason. This also applies to the authorisation to interrupt the limitation period.

You can exercise these rights by sending an e-mail to . We respond within four weeks.

9. Website, members’ platform and cookies

Our website uses no cookies. We do not track your browsing behaviour and share no data with advertising parties. The fonts are hosted on our own server; no connection to another company is needed to display this website.

The members’ platform uses only the cookies needed to log in and to secure the platform: a session cookie, a security cookie against misuse of forms, and — only if you choose to — a cookie to stay logged in. No tracking, no analytics.

10. Complaints

If you have a complaint about the way we handle your data, please contact us first at — we would like to resolve it together. You also have the right to lodge a complaint with the Dutch Data Protection Authority.

11. Changes

We may amend this statement from time to time. The most recent version can always be found on this page, with the date of the last change at the top. We inform members of important changes.

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