Skip naar de inhoud

Rights of data subjects Reporting Office for Organ Transplantation Travel Movements

Who are we?

The core task of the NTS is to allocate organs and tissues from deceased donors to a suitable recipient. Commissioned by the Ministry of Health, Welfare and Sport, the NTS will also manage the Reporting Office for Organ Transplantation Travel Movements as of July 1, 2026. Through this reporting office, the NTS collects data on the travel behavior of residents of the Netherlands who travel abroad for an organ transplant.

Below we outline which personal data we process for the reporting office, for what purpose, and what legal basis we have for doing so. You can also read how long we retain the data and with whom we share it.

Why do we collect the data?
Through the Reporting Office for Organ Transplantation Travel Movements, the NTS collects data on the travel behavior of Dutch residents who travel abroad for an organ transplant. The NTS does this so that policy can be formed aimed at combating potential illegal activities related to organ transplants.


Categories of data subjects whose personal data is processed

Healthcare providers who make a report about a patient who has traveled abroad for an organ transplant are asked a number of questions about the patient and their travel movements. This set of questions has been compiled by the Council of Europe.

The following personal data is processed:

  • Date of transplantation
  • Type of organ transplanted
  • Country where the transplantation took place
  • City and hospital where the transplantation took place
  • Age of the recipient
  • Gender of the recipient
  • Blood type of the recipient
  • Has the recipient previously been treated at the reporting healthcare provider's transplant center prior to traveling abroad for transplantation?
  • Status on the recipient's waiting list
  • Presence of a referral and the reason why the transplantation took place abroad
  • Nationality and place of residence of the recipient
  • Type of donor
  • Age of the donor
  • Sex of the donor
  • Nationality and place of residence of the donor
  • Blood type of the donor
  • Availability of information regarding the transplant team
  • The quality (completeness) of the medical report on the transplantation procedure provided after discharge from the hospital following the transplantation
  • Date of last available follow-up
  • Date of organ loss and cause of organ loss (graft loss)
  • Functioning of the organ one year after transplantation and, if applicable, date of death and cause of death
  • Complications occurring after transplantation that led to immediate hospitalization
  • Infections occurring in the first year after transplantation

Basis for data collection

The collection of data for the Organ Transplant Travel Reporting Desk is laid down in Article 8e of the Body Material Safety and Quality Act. Article 5.3 of the Body Material Safety and Quality Decree and Article 4.2 of the Body Material Safety and Quality Regulation stipulate which personal data may be collected by the reporting desk. This is based on the legal ground of 'task of public interest' combined with the exception ground of 'public health' for the processing of special categories of data under Articles 6(1)(e) GDPR and 9(2)(i) GDPR.

The Ministry of Health, Welfare and Sport is the data controller pursuant to Article 8e of the Body Material Safety and Quality Act. The NTS is the processor of the data collected by the reporting desk.


Who do we share the data with?

The NTS shares the case data collected via the Organ Transplant Travel Reporting Desk with the Council of Europe. The Council of Europe also collects data from other reporting desks regarding travel for organ transplantties. This creates an international overview of travel patterns in the context of organ transplantations.


Where do the data come from?

The data collected by the NTS via the Organ Transplant Travel Reporting Desk originate from healthcare providers who, pursuant to Article 8e of the Body Material Safety and Quality Act, are required to submit a report to the reporting desk if their patient has traveled abroad for an organ transplantation.


How long do we retain data?

The data collected by the NTS via the Organ Transplant Travel Movements Reporting Desk is entered directly into the Council of Europe's registry. This data is not retained by the NTS. The reporter's data is deleted once the report has been completed.

 

Transfer of data to a country outside the EEA

The data collected by the NTS via the Organ Transplant Travel Movements Reporting Desk is not sent by the NTS to organizations outside the European Economic Area (EEA).


Automated decision-making

There is no automated decision-making.

What are your privacy rights?

If we process your personal data, you have a number of privacy rights:

  • Right of access: you can ask which personal data of yours we use. This allows you to check whether we are doing this correctly.
  • Right to rectification: is the personal data we hold on you incorrect or is data missing? Then you can ask us to change or supplement the data.
  • Right to erasure: in some cases you can ask us to delete your personal data.
  • Right to restriction of processing: you can ask us to temporarily stop using your personal data.
  • Right to data portability: you can ask us to transfer your personal data to another organization.
  • Right to object: you can sometimes object to the processing of your personal data.
  • Right to human intervention in decisions: if you receive an automated decision from our end, you can ask us to take a new decision that has been reviewed by a person.

You also have the right to withdraw your consent. Did you previously give us permission to use your personal data, but have you changed your mind? Then you can withdraw your consent. From that moment on, we will no longer process your personal data, unless there is (also) another legal basis for processing your personal data.

Contacting the DPO of the NTS

Do you disagree with how we process your personal data? Then you can contact the Data Protection Officer (DPO) of the NTS. The DPO is independent and ensures that everyone within the NTS complies with privacy legislation.

You can contact the DPO by sending an email to privacy@transplantatiestichting.nl. You can also send a letter to:

Dutch Transplant Foundation
to the attention of the Data Protection Officer
Postbus 2304
2301 CH Leiden

 

File a complaint

Do you have a complaint about the handling of your request by the NTS? Please contact the DPO of the NTS. It is also possible to file a complaint with the Dutch Data Protection Authority.