KRALENDIJK – Zorg en Jeugd Caribisch Nederland (ZJCN) requires its insured individuals to submit various details before they can receive a new health insurance card. In advertisements, insured individuals are informed that a completed and signed data form is necessary to pick up the card.

In addition to basic information like first name, last name, ID number, and date of birth, the form also asks for an email address, mobile phone number, home phone number, and—most notably—their bank account number.

The reason for requiring banking information is not immediately clear. Inquiries to the local privacy watchdog, the College Bescherming Persoonsgegevens BES (CBP-BES), on Monday and Tuesday did not yield an immediate response and seems of little concern to CBP-BES. 

In a comment on LinkedIn by the Secretary of CBP-BES, Roella Pourier, suggests that data collected by organization must serve a justified purpose. “It is ZJCN’s responsibility to inform individuals about the reasons for processing certain data and the legal basis for doing so”, writes Pourier.

Allowed?

An online review suggests that in the European Netherlands, insurers can only request bank details when there is a clear purpose, such as when the insured person is responsible for payment of the premium. If another party, like an employer or the government, handles payments, it is generally not allowed. 

However, the General Data Protection Regulation (AVG) which states this does not fully -and potentially not at all- apply to the Caribbean Netherlands.

Answers

Answers from ZJCN and RCN about the issue are also slow to come. A spokesperson at RCN incidates that a response to written questions from ABC Online Media, should probably not be expected before late Thursday afternoon.