The Dutch Data Protection Authority (AP) has published guidelines for childcare organizations on information sharing in case of suspected criminal offenses, including child abuse.

These clarifications concern the recruitment process. It is thus permitted to ask candidates about any past incidents or the reasons for the termination of a previous employment contract. The authority also specifies that it is possible to collect information online and that there is no limit to the number of referees an organization can contact. These referees can notably be questioned about any doubts they may have regarding a candidate.

The AP also addresses the use of blacklists. While awaiting measures explored by the Ministry of Social Affairs and Employment (SZW) to enable information sharing between different organizations, the authority indicates that structures with multiple establishments can already set up an internal blacklist. It recalls that the GDPR allows the national legislator to establish additional safeguards for the protection of children and confirms its participation in the legal study conducted by the SZW on this subject.