Do you want to list organisations you no longer wish to do business with or employees who have stolen from you? You can create a blacklist. You are not allowed to share this list with others. You should also fulfill the requirements for a blacklist and ensure you respect the rules around privacy.
In the Netherlands, you may only create a blacklist (in Dutch) if you comply with the following requirements:
- You have a justified interest (in Dutch). For example, a threat to your health and safety or preventing fraud or embezzlement
- You cannot achieve your objective by less drastic means
- You can prove that the interests of you and your company weigh heavier than the privacy of the person who is blacklisted
You must register your blacklist (in Dutch) with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens). Business owners can create their own blacklist to keep a record of unwelcome customers or fraudulent employees. If they choose to do so, they must comply with the General Data Protection Regulation (GDPR or Algemene Verordening gegevensbescherming (AvG), in Dutch).
You must also notify the the Dutch DPA if you wish to participate in an existing blacklist. Check the public register (in Dutch), which lists all approved blacklists. If you want to share the personal information on your blacklist with other businesses, you must also ask the Dutch DPA for a preliminary investigation and draw up a protocol.
Viewing a blacklist
If a customer or employee is on your blacklist, you are required to inform them about this. They also have the right to view their personal details (in Dutch) and to ask you to correct or delete them.