Privacy Code of Conduct for Private Investigation Agencies

Code of conduct regarding privacy

Table of Contents

Privacy Code of Conduct for Private Investigation Agencies

As a licensed private investigation agency (POB) supervised by the Ministry of Justice and Security, Nefesh Investigations attaches the highest value to the protection of privacy. We act strictly in accordance with the Privacy Code of Conduct for the private investigation sector.

1Compliance and Legislation

Our methods are fully in line with statutory legislation, including the Dutch Private Security Organizations and Investigation Agencies Act (Wpbr) and the General Data Protection Regulation (GDPR). Our code of conduct is approved by the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) and forms the ethical and legal foundation of every investigation we conduct.

2Proportionality and Subsidiarity

Before any proposed investigation, we perform a strict assessment based on the principles of proportionality and subsidiarity:

  • Proportionality: The infringement on the private life of the subject must not be disproportionate to the interest of the client to be served.
  • Subsidiarity: The objective of the investigation cannot reasonably be achieved in a different way that is less intrusive for the subject.

3Lawful Basis for Investigation

Nefesh Investigations only conducts investigations when there is a lawful basis. In most cases, this is the legitimate interest of the client (such as detecting fraud, theft, or defending a legal position in court), provided this interest outweighs the privacy interest of the data subject.

4Rights of Data Subjects

Data subjects (the individuals being investigated) have specific rights under the GDPR, such as the right of access and rectification. In accordance with the Privacy Code of Conduct, the exercise of these rights may be temporarily suspended or restricted if necessary to safeguard the effectiveness of the ongoing investigation or the safety of individuals.

5Reporting and Data Transfer

The results of our investigation are documented in an objective and factual report. We report only facts relevant to the purpose of the investigation. Personal data of third parties collected incidentally and found irrelevant are immediately removed from the file and not transferred to the client.

6Supervision and Complaints

Nefesh Investigations operates under an official license granted by the Ministry of Justice and Security. Complaints regarding alleged violations of privacy or the code of conduct can be filed in accordance with our official complaints procedure, and if desired, reviewed by independent sectoral bodies.