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Confidentiality Policy

At Robbeburg, we take confidentiality seriously. As a volunteer-run, non-profit association, trust, safety, and responsible handling of information are essential to how we operate. These guidelines explain how confidential information is handled by those acting on behalf of Robbeburg. (For information about how Robbeburg processes personal data, please refer to the Privacy Policy.)

Rules & Guidelines

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1. General duty of confidentiality

 

Members of the Management Board and volunteers acting on behalf of Robbeburg are expected to treat all non-public information they learn through their role as confidential. This responsibility applies during their time with the Association and continues after their involvement ends.

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  • ​Board members carry a heightened duty of care and responsibility under applicable law, including the Wet Bestuur en Toezicht Rechtspersonen (WBTR). Their confidentiality obligations continue after resignation or dismissal.

  • Volunteers are expected to follow these rules in good faith, in proportion to their role, access, and responsibilities. While volunteers do not carry the same legal or governance responsibilities as Board members, confidentiality still applies to the information they receive.

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Confidential information may include, but is not limited to:

  • personal data of members, volunteers, children, families, donors, partners, or service providers

  • financial information and internal documents

  • internal discussions, opinions, and decision-making

  • draft materials, internal reports, and unpublished plans

  • complaints, safety reports, investigations, and disciplinary matters

2. Forms of communication covered

 

Confidentiality applies regardless of how information is shared or stored. This includes:​

  • in-person conversations

  • phone or video calls

  • emails

  • text messages

  • WhatsApp communications (both direct messages and group chats)

  • other messaging or collaboration platforms

  • written notes, agendas, drafts, minutes, and internal documents

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Information shared through any of these channels is considered confidential Association information.​

3. No “informal” exception

 

Using informal communication does not make information informal. Information shared via WhatsApp, private messages, or casual conversations remains confidential and must not be shared, forwarded, screenshotted, summarized, or disclosed unless the Management Board has explicitly decided that it may be shared.​ This applies to both Board members and volunteers, within the scope of the information they receive.

4. Privacy, photography, and use of images & videos

 

Robbeburg values both the creation of personal memories and the protection of privacy within its community. Particular care is taken with respect to photographs and recordings involving children.

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Personal photography and video by community members​

Photography and video recording for personal, non-commercial use within the Robbeburg space is permitted under the following conditions:

  • Community members may photograph or record their own child(ren) for personal use.

  • Children other than one’s own may not be photographed or recorded without the explicit consent of the relevant parent or legal guardian.

  • Care must be taken to avoid capturing other children or individuals in a recognizable manner, particularly in group settings.

Personal photographs or recordings must not be shared publicly if they identify other children, families, or individuals, unless explicit consent has been obtained.

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Photography and recording by the Association (official use)

The Association may take photographs or videos, whether by volunteers or hired professionals, during activities, classes, or events for communication, documentation, or promotional purposes, including use on official Robbeburg channels such as its website and social media.

  • Participants will be informed when photography or recording may take place.

  • Publication will only occur with explicit consent from the individuals concerned or, in the case of children, from a parent or legal guardian.

  • Consent may be:

    • withheld entirely, in which case the image or recording will not be published

    • granted subject to conditions (for example, faces being blurred or otherwise not identifiable)

    • granted without restriction

Images or recordings of children will never be published without parental or guardian consent.

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Professional events and external hosts

For professional events, workshops, or activities organized by the Association or by third parties operating within the Robbeburg space:

  • Participants must be informed in advance if photography or recording will take place.

  • External hosts, facilitators, and professionals are expected to comply with Robbeburg’s confidentiality, privacy, and consent standards.

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Duty of care and discretion

All persons present in the Robbeburg space are expected to act with care and discretion when taking, using, or sharing photographs or recordings. In cases of uncertainty, restraint must be exercised and consent must be obtained before photographing, recording, or sharing images. Respect for privacy supports a safe, respectful, and trusted environment for children, families, volunteers, and the wider community.

5. Use of personal devices and accounts

 

When using personal phones, computers, or accounts for Robbeburg-related communication:

  • Board members must take proactive and reasonable steps to safeguard confidential information, in line with their governance responsibilities.

  • Volunteers must take reasonable care to prevent unauthorized access and avoid unnecessary sharing, storing, or retaining confidential information.

6. When disclosure is allowed

 

Confidential information may only be shared if:

  • the Management Board has explicitly approved the disclosure; or

  • disclosure is required by law or by a competent authority.

 

If disclosure is legally required, the Board Chair (or another designated Board member) must be informed as soon as possible.

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Volunteers should never independently disclose confidential information to third parties and must refer any requests for information to the Management Board.

Why confidentiality matters

 

Confidentiality helps us:

  • protect the interests of the Association

  • safeguard children, families, volunteers, staff, and partners

  • enable honest and safe internal discussions

  • comply with legal and governance duties under the WBTR

  • maintain trust within the Robbeburg community

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Under the WBTR, Board members are jointly and individually responsible for proper governance and safeguarding the Association’s interests. Volunteers support this framework by handling information responsibly within their role.

Why breaking confidentiality is serious

 

A breach of confidentiality by a Board member or volunteer can:

  • damage trust within the organization

  • undermine Robbeburg’s safety and governance culture

  • violate privacy laws

  • harm individuals or the Association’s reputation

 

For Board members, serious breaches may also constitute mismanagement under the WBTR and lead to internal measures or personal liability.

 

For volunteers, breaches may result in:

  • removal from their role

  • restricted access to information

  • other proportionate actions, depending on the situation

Taking action against breaches of confidentiality

 

Anyone (members of the Robbeburg community, Board members, non-members, visitors, anyone hired by the Association to perform services at events, maintenance of the space, etc.) may report a breach of confidentiality via our Complaint Procedure. The Robbeburg Conflict Protocols will be used to handle incidents of confidentiality breaches.

Relationship to the Privacy Policy

 

This Confidentiality Policy governs the internal handling, sharing, and protection of non-public information by Board members, volunteers, and others acting on behalf of the Association.

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The processing of personal data by the Association itself is governed by the Robbeburg Privacy Policy, which sets out how personal data is collected, used, stored, and protected in accordance with applicable privacy laws.

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