Privacy statement

Which personal data do we process?

Avans may process the following personal data:

• Identification data;
• Name, address and contact details;
• Images and video materials;
• Financial data;
• Education data, such as enrolment information and study progress data;
• Communication sent by, to, or about the individual concerned;
• Data about attendance, availability, location and internet use;
• Employment data;
• Data about the use of our network, websites and apps, such as browser data, device data, location data and online behaviour.

Learning Analytics

For Learning Analytics, we may also process special categories of personal data and sensitive personal data. This may include information about study progress and personal or social factors that may affect a student’s studies, such as study pressure or a need for additional support.

Why do we use this personal data?

We use this personal data for the following purposes:

• Recruiting and selecting new students;
• Supporting orientation of choice of study programme and providing information to prospective students; 
• Student administration;
• Organising and providing education, including assessments and examinations;
• Providing learning materials, both digital and non-digital;
• Internal and external communication;
• Recording examination results;
• Issuing certificates, diplomas and academic degrees;
• Preparing and carrying out agreements with students;
• Complying with legal obligations and providing study guidance and advice;
• Student engagement and relationship management;
• Promotional activities, marketing and alumni relations;
• Supporting students with disabilities or functional limitations;
• Providing help, advice and personal guidance to students, including support for study-related, psychological, social or emotional issues;
• Research and quality improvement in education;
• Maintaining contact through information messages, newsletters and small gifts;
• Sending surveys, including surveys for rankings;
• Organising events;
• Inviting students and alumni to advisory activities;
• Volunteering and mentoring programmes;
• Fundraising activities;
• Recording alumni career development for the purposes listed above;
• Safety and security;
• Organisational analysis, internal controls, development and management reporting;
• Supporting accreditation procedures;
• Financial administration, including calculating and collecting tuition fees and transferring outstanding claims to third parties when necessary;
• Managing purchasing and payment systems;
• Managing IT procedures and legal matters;
• Handling requests, complaints, appeals and disputes;
• Conducting market research and organisational analysis;
• Creating development and management reports;
• Library services;
• Physical and digital archiving;
• Participation councils and elections;
• Preventing, identifying, investigating and resolving cybersecurity incidents, ensuring the availability and stability of ICT services, and monitoring and protecting the Avans IT infrastructure.

Learning Analytics

Avans processes personal data for Learning Analytics to provide tailored advice about the quality and design of education. The data is also used to support the personal development and guidance of individual students. By analysing this data, Avans can further improve the quality of its advice, support and educational opportunities.

Which personal data do we process?

Avans may process the following personal data:

• Identification data
• Name, address and contact details
• Background information
• Images and video materials
• Financial data
• Employment, performance and appraisal data
• Communication sent by, to, or about the individual concerned
• Data about attendance, absence, availability, location and internet use
• Education level and diplomas
• Employment history
• Data about the use of our network, websites and apps, such as browser data, device data, location data and online behaviour.

Why do we use this personal data? 

We use this personal data for purposes such as:

• Recruitment and selection
• Preparing and carrying out employment contracts, including employment conditions
• Preparing and carrying out employment contracts when an employee transfers to, or is temporarily assigned to, another organisational unit within the Avans group
• Determining salary entitlements and managing payroll administration
• Managing employee benefits and carrying out internal and external audits
• Personnel administration and HR management
• Supervising and managing an employee’s work
• Organising occupational health services, employee support services, and creating a safe working environment
• Education, training and professional development
• Managing dismissals, post-employment benefits and pension rights
• Maintaining the administration of the association of former employees
• Considering or carrying out dismissal procedures
• Transferring outstanding claims to third parties when necessary
• Financial administration
• Internal control and corporate security
• Managing purchasing and payment systems
• Managing IT procedures and legal matters
• Internal and external communication
• Organisational analysis, development and management reporting
• Preparing and carrying out agreements with customers, consumers, suppliers and business partners
• Relationship management, marketing and market research
• Handling disputes, complaints, appeals and objection procedures
• Audits by accountants or government auditors
• Managing physical access and access-control systems
• Managing websites, the iAvans intranet and Microsoft Teams
• Library services
• Physical and digital archiving
• Participation councils and elections
• Sending information, newsletters and small gifts
• Preventing, identifying, investigating and resolving cybersecurity incidents
• Ensuring the availability and stability of ICT services
• Monitoring and protecting the Avans IT infrastructure

Avans may provide information to government and semi-government organisations where required for the implementation of laws and regulations. Information may also be shared with organisations whose activities are based on legal obligations or statutory regulations.

Which personal data do we process?

When you visit our website, we may process the following personal data:

• Browser data
• Device data
• Location data
• Information about how you use our websites

Why do we use this personal data?

We use this personal data for:

• Marketing and market research
• Handling disputes, complaints, appeals and objection procedures
• Website content management
• Cybersecurity
• Analytical purposes, such as understanding and improving the use of our websites

These activities help us keep our websites secure, improve user experience, and better understand how visitors use our online services.

Which personal data do we process?

We may process the following personal data of visitors to our buildings and campuses:

• Contact details
• Images and video materials

Why do we use this personal data?

We use this personal data for:

• Safety and security
• CCTV monitoring
• Managing parking facilities
• Handling disputes, such as complaints, appeals and objection procedures

Which personal data do we process?

During research projects, we may process:

• Research data*
• Identification data
• Contact details
• Images, audio recordings and video materials
• Financial data
• Employment data
• Digital data

We may also process special categories of personal data, such as information about health, racial or ethnic origin, genetic data or biometric data.

Research involving personal data is carried out in accordance with the GDPR and the Dutch Code of Conduct for Research Integrity. Where necessary, the Avans Ethics Committee reviews research projects before they begin.

Why do we use this personal data?

We use this personal data for:

• Conducting and publishing scientific research
• Conducting and publishing practice-based research
• Conducting statistical research
• Internal and external communication about research activities
• Supporting integrity investigations
• Managing and operating IT systems and procedures
• Handling disputes, complaints, appeals and objection procedures
• Physical archiving
• Digital archiving.

This category includes organisations such as internship providers, graduation project companies and clients.

Which personal data do we process?

We may process the following personal data:

• Name
• Contact details
• Company information
• Images, audio recordings and video materials
• Communication sent by, to, or about the individual concerned

Why do we use this personal data?

We use this personal data for:

• Preparing and carrying out agreements
• Corporate security
• Managing and operating IT procedures and systems
• Handling legal matters
• Internal and external communication
• Organisational analysis
• Establishing and carrying out agreements with customers, consumers, suppliers and business partners
• Relationship management
• Marketing and market research
• Handling disputes, including complaints, appeals and objection procedures
• Audits by accountants and government auditors
• Managing websites, the iAvans intranet and Microsoft Teams

Which personal data do we process?

We may process the following personal data:

• Name
• Contact details
• Company information
• Images, audio recordings and video materials
• Communication sent by, to, or about the individual concerned

Why do we use this personal data?

We use this personal data for:

• Preparing and carrying out agreements
• Corporate security
• Managing and operating IT procedures and systems
• Handling legal matters
• Internal and external communication
• Organisational analysis
• Establishing and carrying out agreements with customers, consumers, suppliers and business partners
• Relationship management
• Marketing and market research
• Handling disputes, including complaints, appeals and objection procedures
• Audits by accountants and government auditors
• Managing websites, the Avans intranet and Microsoft Teams

In some situations, we process your personal data because you have given us permission to do so.

We only process personal data when a person has given informed, specific, freely given and explicit consent for the stated purpose.

You can give consent, for example, by:

• Ticking a checkbox
• Completing and submitting an online form
• Signing a paper form
• Giving verbal permission

You can withdraw your consent at any time. From that moment on, Avans will no longer collect new personal data based on that consent.

Withdrawing consent does not affect the lawfulness of any processing that took place before the consent was withdrawn. If you wish to have your previously collected personal data deleted, you can use your right to erasure. You can find more information about this under “Your rights in relation to your personal data”.

Examples of processing based on consent include:

• Sending information about Avans to prospective students
• Using photographs and videos
• Conducting research
• Learning Analytics projects that involve special categories of personal data

We process personal data when it is necessary to perform an agreement between Avans and another party.

In such cases, the processing of personal data forms part of the agreement that has been accepted by the other party.

Examples include:

• Employment contracts between Avans and employees
• Educational agreements between Avans and students
• Procurement and purchasing processes

In some cases, Avans is legally required to process personal data.

Examples include:

• Maintaining student records for issuing degrees and diplomas
• Providing information to government authorities regarding tax and employment obligations

A vital interest is an interest that is necessary to protect someone's life or health.

This legal basis applies in situations where a person is unable to give consent and immediate action is required.

Examples include:

• A student or employee is in immediate danger and is unconscious or unable to provide consent
• A person is injured on campus and cannot give permission to process personal data

In some situations, Avans may process personal data because it serves the public interest.

As a university of applied sciences, Avans has a public task: providing higher education.

These processing activities are based on specific legislation and government policies relating to education.

A legitimate interest exists when all of the following conditions are met:

• Avans has a real and legitimate interest
• The processing is necessary to achieve that interest
• The interests and rights of the individuals involved have been carefully balanced against the interests of Avans

Avans only relies on a legitimate interest after carefully assessing the privacy interests of those involved.

Examples of processing based on a legitimate interest include:

• Monitoring network and internet use to protect the security of the Avans network
• Informing existing business contacts about Avans activities
• Preventing and combating fraud and other unlawful activities
• Learning Analytics projects that do not involve special categories of personal data

Additional information:

1. Avans provides personal data such as enrolment details, examination results, study progress and deregistration information to the Education Executive Agency (DUO), including the Central Register for Enrolment in Higher Education (CRIHO), when required by law.
2. Avans may share information about the study progress of former students with the educational institution where those students previously studied.
3. For research aimed at improving quality, students may give permission for external information to be linked to Avans records, for example through email addresses. Personal data from the HBO Monitor may also be linked to Avans records through the student number.
4. Email addresses of students and alumni may be shared each year with Studiekeuze123 and the Research Centre for Education and the Labour Market (ROA). This is necessary for participation in the National Student Survey (NSE) and the HBO Monitor.
5. Personal data may only be linked to Avans records following a written and justified request from an internal or external party. A recognised and specific purpose must exist.
6. The following rules apply to the collection and sharing of personal data with foreign educational institutions, internship organisations and the Immigration and Naturalisation Service (IND):
   • If a student studies or completes an internship abroad, Avans may share relevant personal data and study results with the foreign educational institution or internship organisation involved.
   • For students temporarily studying at Avans, we may request relevant personal data and study results from their home institution.
   • Under the Dutch Aliens Act 2000, prospective students who do not have Dutch nationality must provide additional documents. These documents are needed for enrolment and to demonstrate a valid residence status.
   • By enrolling at Avans, non-EEA students agree, under the Code of Conduct for International Students in Higher Education, that Avans may inform the IND if the enrolment ends or if the student no longer makes sufficient study progress.
7. Avans considers students to be independent and responsible for their own studies. For this reason, Avans does not share information with parents or guardians, even when a student is legally a minor.

Additional information:

1. Avans only shares personal data with other parties when required by law or when necessary for:
   • Employment benefits and employment conditions;
   • Payroll administration;
   • The administration of benefits following the end of employment;
   • The administration of the association of former employees;
   • Education and training;
   • Occupational health and medical services;
   • Corporate security;
   • The transfer or temporary placement of an employee within another part of Stichting Avans;
   • Dismissal procedures;
   • Transferring outstanding claims to third parties;
   • Handling disputes;
   • Audits by accountants or government auditors;
   • Employee satisfaction surveys and similar organisational research.
2. Avans may also provide personal data to government and semi-government organisations where this is necessary for the implementation of laws and regulations.
3. In certain situations, Avans may share personal data with third parties when this is in the interests of employees. In such cases, the employee or their legal representative will be informed in advance and given a reasonable opportunity to object to the disclosure.

Avans takes photographs and videos on various occasions. These materials may be used for educational purposes, recruitment activities, or to show the work and achievements of students and employees.

Examples include internships, practical classes, other educational activities, and events.

You may appear in this material.

For portrait photographs and similar situations, Avans always asks for your explicit, specific and written consent in advance.

Avans handles images and video with care. We do not publish photographs or videos that could cause harm to students, employees or other individuals.

For spontaneous, non-staged situations, Avans does not request written consent. In these cases, the use of images may be based on a legitimate interest. However, you can always inform the photographer or camera crew that you do not wish to appear in photographs or videos.

Images and video may be shared with photographers, camera crews or other parties working on behalf of Avans for publications and communications. Material may also be shared within collaborations involving Avans or used for journalistic purposes.

When making recordings, Avans generally follows the recommendations of the Dutch Data Protection Authority.

According to these recommendations, recordings that show students may only be made in exceptional situations when there is a clear and necessary reason.

Avans has translated these recommendations into practical rules.

The main rules are:

• Classes or educational activities in which students are not visible and cannot be heard may be recorded.
• These recordings may later be made available to other participants who wish to review the session.
• Classes or educational activities in which students are visible or audible may not be recorded unless this is necessary.

Avans considers recording necessary in the following situations:

• A lecturer uses recordings to provide feedback to a student or to assess a student.
• The lecturer has assessed whether recording is genuinely necessary. If the same purpose can be achieved with a less intrusive method, such as an audio recording or written report, that method should be used instead.
• Recordings are made as evidence for examinations or for archiving purposes. These recordings may not be reused as teaching material for other classes or educational activities.
• The lecturer always decides whether a class or educational activity will be recorded.

Students are not allowed to record classes or educational activities.

For Avans employees, specific implementation rules apply.

Under the Avans house rules, students may not record, publish, distribute through social media, or otherwise process classes or educational activities involving Avans without permission.

Avans uses visible and, in some cases, hidden CCTV cameras on its campuses, in its buildings and on its grounds.

People may be identifiable in these recordings. This means that Avans processes personal data for the following purposes:

1. Protecting the safety and health of one or more individuals, such as students and employees;
2. Securing buildings, grounds and access points;
3. Preventing theft of or damage to property in Avans buildings and on Avans premises;
4. Recording possible incidents.

Avans collects and uses CCTV footage for these security purposes on the basis of its legitimate interest.

Recorded CCTV footage is deleted after four weeks.

The Avans CCTV Policy explains in more detail how Avans uses and manages camera surveillance.

In 2021, Avans carried out a limited number of pilot projects using online proctoring.

Online proctoring is a form of digital assessment that allows students to take examinations remotely.

These pilot projects included safeguards that were established in advance.

Since these pilots, Avans no longer uses online proctoring for examinations.

You have the right to know whether Avans processes your personal data.

If Avans processes your personal data, you have the right to access that data.

You have the right to ask Avans to delete your personal data.

For example, this may apply when the personal data is no longer necessary for the purpose for which it was collected or processed, or when you withdraw your consent.

Avans cannot delete personal data when a legal obligation requires us to process or retain that data.

Personal data may also need to be retained if it is required to establish, exercise or defend a legal claim.

You have the right to have inaccurate personal data corrected.

You also have the right to complete incomplete personal data if this is necessary for the purpose of the processing.

If you are a student or employee, you may be able to update certain personal data yourself through Osiris or the HR self-service portal.

You have the right to receive the personal data that Avans processes about you in a structured, commonly used and machine-readable format.

This right applies to personal data that you, or someone acting on your behalf, have provided to Avans and that is processed using automated systems.

If Avans processes your personal data on the basis of your consent, you may withdraw that consent at any time.

Any processing that took place before the consent was withdrawn remains lawful.

You have the right to ask Avans to limit the processing of your personal data in one of the following situations:

1. The personal data may be inaccurate;
2. The processing is unlawful;
3. The personal data is no longer needed;
4. You have objected to the processing.

If Avans processes your personal data on the basis of a legitimate interest, you have the right to object because of your particular situation.

Avans will then stop processing your personal data unless we can demonstrate compelling legitimate grounds to continue the processing.

These grounds must outweigh your interests, rights and freedoms.

Avans may also continue processing if the personal data is necessary to establish, exercise or defend a legal claim.

When you submit an objection, Avans will carefully balance your interests against the interests of Avans and any relevant third parties before making a decision.