Table of Contents

1. Data Privacy and Protection Principles
2. General Provisions
3. Lawful, fair and transparent processing
4. Lawful purposes
5. Data minimisation
6. Accuracy
7. Archiving / removal
8. Security
9. Data Breaches
10. Arbitration
11. Contacts

1. Data Privacy & Protection Principles

We are committed to processing your data in accordance with principles outlined in Article 5 of GDPR. These principles aver that we must take due care with your data and limit our use to what’s necessary for collection and retention. The full text of article 5 principles can be viewed by clicking on the button below.

2. General provisions

1. This policy applies to all personal data [PII] held by us and on our behalf by Data Processors.
2. Our Data Protection Officer shall take responsibility for our ongoing compliance with this policy.
3. This policy shall be reviewed at least annually.
4. We are registered with the (examples) (Data Protection Commission [DPC] , Information Commissioners Office [ICO], / French Data Commissioners Office[CNIL], / German Federal Data Protection Office [BfDI] ) as an organisation that processes personal data.

3. Lawful, fair and transparent processing

1. To ensure processing of your data is lawful, fair and transparent, we maintain a “Record of Processing Activities” ROPA.
2. The ROPA shall be maintained and reviewed at least annually.
3. Individuals have the right to access their personal data free of charge in an accessible electronic format.
4. Such requests, known as Data Subject Access Requests or DSAR’s made to us shall be provided within 28 days of receipt. (*exceptions may apply)

4. Lawful purposes

1. As required by GDPR, all data processed by us is conducted on lawful basis. This basis includes the following four categories; Consent, Contract, Legal Obligation & Legitimate Interests (see Irish DPC for sample guidance).
2. This lawful basis is recorded in our record of processing activities.(see ROPA example)
3. Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data.
4. Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent will be clearly available and systems will be in place to ensure such revocation is reflected accurately on our systems.

5. Data minimisation

1. We shall ensure that personal data processing safeguards are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
2. Data minimisation techniques such as anonymisation will be used where possible. This is in line with our Privacy by Design (PbD) and default approach to data privacy in our data privacy policy.

6. Accuracy

1. We shall take reasonable steps to ensure personal data is accurate.
2. Where necessary for the lawful basis on which data is processed, steps shall be put in place to ensure that personal data is kept up to date.

7. Archiving / removal

1. To ensure that personal data is kept for no longer than necessary, we shall put in place an archiving provision in our company data privacy policy for each area in which personal data is processed and review this process annually.
2. The archiving policy shall consider what data should/must be retained, for how long, and why.

8. Security

1. We shall ensure that personal data is stored securely using modern software that is kept-up-to-date.
2. Access to personal data shall be limited to personnel who need access and appropriate security should be in place to avoid unauthorised sharing of information.
3. When personal data is deleted this will be done safely such that the data is irrecoverable. (e.g. FIPS standard compliant)
4. Strong authentication (MFA) will be used for administrators of personal data on our systems
5. Personal data stored and transmitted on our systems will be encrypted using the latest encryption standards.
6. Appropriate back-up and disaster recovery solutions shall be in place.

9. Data Breach

In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data, We shall promptly assess the risk to your data and if appropriate report this breach to the data protection authority (e.g. ICO, CNIL)
In instances where where a breach is likely to result in a high risk to your personally, we will inform you within 72 hours as required by the breach notification rules.

11. Contact Information

Our Data Protection Officer is [John Smith] whose email address is [email protected] and whose (sample) address is [Security Training Slides, 1 Sansome st, San Francisco 94101].

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