Committee Undesirable Behaviour

Privacy is a fundamental right that everyone can invoke. There are strict rules for the processing of personal data.

Audio-recordings are always made during hearings of the Whistleblowers Committee (based on art. 4.8 paragraph 8 Whistleblower Regulations 2023), the Committee Scientific Integrity (based on art. 4.9 paragraph 9 EUR Complaints Procedure Scientific Integrity 2020) and the Committee Undesirable Behaviour (based on art. 4.9 paragraph 10 EUR Complaints regulations Undesirable Behaviour 2020). The audio-recordings are only stored on devices and servers of the EUR.

Recording conversations may be necessary based on the so-called ‘justified interest’ of the organization. This means that an organization may use audio-recordings for the normal business operations or daily management of the organization. In doing so, a balance of interests must be made between the interests of the organization and the interests of those whose voices are being recorded.

The EUR has made the following balance of interests:

1. The audio-recordings are made for the purpose of checking the reporting and the accuracy of the reporting. Careful reporting is of great importance when handling reports to the Whistleblowers Committee, the Committee Scientific Integrity and the Committee Undesirable Behaviour. The purpose is not to process biometric personal data (voice).
2. The audio-recordings are only made for internal use (classified as secret) and are not provided to interested parties. If requested, interested parties will be given the opportunity to verify the accuracy using the audio-recording.
3. The audio-recording will be destroyed after the parties have confirmed the accuracy of the reporting for as long as the procedural interest requires this. When the board has given its final judgment (CWI) and the term for submitting an application to the National Ombudsman has expired, the audio-recordings will be destroyed.
4. If the audio-recording is used as an electronic report, the report will be kept for as long as the Archives Act 1995 prescribes this.
5. An accurate representation of the hearing is in the interest of truth-finding and therefore in the interest of those involved.
6. The consequences for those involved due to an infringement of privacy have been limited to a minimum by the aforementioned safeguards.

On this basis, the interests of the EUR in processing the personal data for the purpose of reporting outweighs the interests of those involved due to an infringement of the right to privacy.

Those involved are not allowed to make an audio-recording, this is to safeguard the privacy of all. This will be clearly stated at the start of the hearing. 

For further information regarding data protection, we refer you to the Privacy Statement; if you have any questions, please contact Legal Procedures.