Privacy Policy

Privacy Policy

Carla Houben -coach, facilitator of Restorative Circles and mediator- has read and aims to comply with the General Regulations concerning the Protection of Personal Data (‘Algemene Verordening Gegevensbescherming – AVG) which enters into force per 25-05-2018.

Carla Houben requests clients to provide only a minimum of personal data required for setting up a coaching agreement, a restorative circle or a mediation contract:
name, function, telephone number and mail address of the participant(s), as well as -if relevant- name, address, telephone number and mail address of the employer and/or HR manager.
Carla Houben herself does not have any employees.

Such personal data is usually voluntarily supplied by the participants, to be used during the coaching, restorative circle or mediation. Special or sensitive data is not supplied nor stored. Personal data is not processed automatically nor processed by third parties for the foundation. Personal data is shared with third parties with permission or in case of a legal obligation to do so; it is never sold. The site only has functional and analytical cookies which do not track personal behaviour. There is a form on the website, but usually people phone or mail directly. The form is not connected to a database but generates a mail through the hosting server which keeps the security up-to-date. Carla Houben is responsible for timely reporting any data leaks to the Authority on Personal data (‘Autoriteit Persoonsgegevens’).

After finishing a coaching, a restorative circle or a mediation, personal data is removed from the cell phone and iCloud and either completely deleted or stored in a back-up computer (protected by a password) for a maximum of seven years. A mediation file has to be kept for seven years; after that it is destroyed. For notes on a restorative circle or coaching there is no storage obligation, but sometimes people return. Therefore, here too a term of seven years is adhered to. Details concerning remuneration must be kept for a maximum of ten years.

All those whose personal data (name, telephone number, mail and possibly address) is received, used -to make contact- and stored by MiNT Coaching respectively MiNT Mediations, have the following rights based on the AVG:
– the right to see one’s own personal data (usually self-supplied)
– the right to have this data corrected
– the right to have this data deleted
– the right to limit the use of this data
– the right to protest against using this data
– the right to request the transferral of this data (data portability) and
– the right to file a complaint with the Autoriteit Persoonsgegevens.

When an explicit written request concerning these rights is submitted to Carla Houben, if possible she will react within one month. During vacations, this period may be extended by two months. If it is not possible to react concerning the contents of the request within one month (or in case of vacations, within three months), the person concerned may be informed that the answer may take another one month at the most. No costs will be charged for the handling of such a request, unless the request is excessive or illegitimate.

These Privacy Regulations have been adapted in Amsterdam on 20180427