May I record a customer or employee national service number (BSN)?
Using the Dutch BSN is only allowed when a law lets you or requires you. Employers, healthcare, education and pensions are covered; most other SMB relationships are not.
Try this first
- 1An employer? You may and must process the BSN of employees for payroll and wage tax filings.
- 2Supplying healthcare or working in healthcare? BSN inside the care chain is regulated via the Wabvpz law.
- 3If you ask BSN for identification or as a customer ID in a normal B2C or B2B context, that is not permitted. Use your own customer number.
- 4BSN landing on your desk unsolicited (for example on an ID copy)? Redact it as soon as possible or keep it encrypted only if you genuinely need it for a legal obligation.
- 5Record the legal basis for any BSN processing in your processing register. No basis, no BSN.
When to bring us in
Unsure if your sector is covered by a specific law that allows BSN, check with your trade body or a GDPR lawyer.
See also
- Does NIS2 apply to my company?Two questions decide it: are you in a listed sector, and do you meet the threshold from Recommendation 2003/361/EC (more than 50 FTE and more than EUR 10M turnover or balance sheet). Below that you are only indirectly in scope, via your customers. The threshold determines whether you are an important or essential entity depending on sector.
- What changes with the Dutch Cyber Security Act?The Cyberbeveiligingswet is the Dutch implementation of NIS2. Track NCSC for the exact effective date and the lower regulations.
- Am I personally liable as a director under NIS2?Yes. The board is accountable for approving and overseeing the cyber measures. Severe negligence can become personal.
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