As founder and managing director of Plimsoll Management Consultancy I have been dealing with privacy regulations since 1984. Initially few legislation, if any, existed in this area and people weren’t too much aware either.
In the nineties Plimsoll became a member of the former branch society (OAWS) for Executive Search and Recruitment which at the time was busy drawing up its own rules and procedures for integrity, discretion and protection of personal data by its member firms.
It was also the time of the initially reluctant entry of digitalisation. My first database in 1984 was a Rolodex with some 300 names, but already in 1986 I bought our first PC, with relatively advanced database software.
Roughly in that same period, we became an active partner in successive international partnerships and notably in such environments it quickly became clear that the regulations regarding personal data differed considerably; per company, but also per country.
Taking lessons from these different legislations and rules of conduct and bearing in mind our increas-ingly international clientele and candidate base, Plimsoll by her own right had already drawn up strict internal rules for the registration and protection of personal data. We also legally recorded our data-bases, notifying the relevant authorities (Registratiekamer) at an early stage.
With the growth of our company it became essential to include these processes in a more extensive manual, in which the various business processes were described. It was also the time when quality procedures (ISO) and food safety standards (HACCP) got plenty of attention and we capitalized on these trends with targeted advice products.
Around the year 2000 I wrote the following line in our company handbook, which every employee was handed when starting employment:
General guidelines regarding Integrity and discretion
An important part of the activities of Plimsoll Management Consultancy concerns job placement in the broadest sense of the word whereby candidates on the one hand and clients on the other rely on the integrity and discretion of Plimsoll and its employees. Apart from the moral obligation which Plimsoll and its employees bear in this respect in relation to its stakeholders, this also involves an essential com-mercial interest.
After all, at the moment that either a candidate or a client does not put the fullest trust in the integrity and discretion of Plimsoll and its employees, they will either not use the services of Plimsoll or do not give the complete information necessary for the proper execution of the services of Plimsoll and thus not enable Plimsoll to perform its tasks properly.
It is therefore of the utmost importance that Plimsoll and its employees not only do everything to ensure that integrity and discretion, but also, in all its actions, be aware of the effect, rightly or wrongly, it has on the aforementioned trust of candidates and clients.
In any case where there is a doubt about the correctness of the actions in the light of the above, and this cannot be clearly read from the described procedures, the employee must, without exception with regard to the nature of the doubt or the seniority of the employee, consult the management.
Quite clear: the above, rather simple, instruction will no longer suffice in 2018. With the advanced digitisation the world is more transparent, but at the same time much more complex. Yet the intention remains unchanged.
The introduction of the UAVG / GPDR has not made life easier for us and yet again has led to considerable changes in our processes (and costs). Nevertheless -mindful of our name giver Samuel Plimsoll, who was a fanatic campaigner for better rules and regulations for human rights and safety in the shipping industry in the 19th century- I have warmly welcomed the arrival of the new regulations and I have looked forward to the implementation with confidence.
Welcomed, because although we ourselves have and always had the intention to do everything “the right way”, in many other organizations and in many other countries privacy is not a first priority yet.
With confidence, because for decades we have been used to handle personal data with extreme care.
All in all: a new phase and new rules, to which we wholeheartedly give our cooperation, which we propagate with conviction and which our candidates, customers and other stakeholders can quote us on.
Rotterdam, June 2018
Dick (D.H.) Binkhorst
Founder and director / shareholder
Plimsoll Management Consultancy bv