Confidentiality

GDPR Compliance Statement

    Introduction

    The EU General Data Protection Regulation (“GDPR”), comes into force across the European Union on 25th May 2018 and brings with it the most significant changes to data protection law in two decades. Based on privacy by design and taking a risk-based approach, the GDPR has been designed to meet the requirements of the digital age.

    The 21st Century brings with it broader use of technology, new definitions of what constitutes personal data, and a vast increase in cross-border processing. The new Regulation aims tostandardise data protection laws and processing across the EU; affording individual stronger, more consistent rights to access and control their personal information.

    Our Commitment

    Altscale (‘we’ or ‘us’ or ‘our’),are committed to ensuring the security and protection of the personal information that we process, and to provide a compliant and consistent approach to data protection. We have always had a robust and effective data protection program in place which complies with existing law and abides by the data protection principles. However, we recognise our obligations in updating and expanding this program to meet the demands of the GDPR.

    Altscale, are dedicated to safeguarding the personal information under our remit and in developing a data protection regime that is effective, fit for purpose and demonstrates an understanding of, and appreciation for the new Regulation. Our preparation and objectives for GDPR compliance have been summarised in this statement and include the development and implementation of new data protection roles, policies, procedures, controls and measures to ensure maximum and ongoing compliance.

    How We are Preparing for the GDPR

    Altscale already have a consistent level of data protection and security across our organisation, however it is our aim to be fully compliant with the GDPR by 25th May 2018.

    Our preparation includes:

• Information Audit - carrying out a company-wide information audit to identify and assess what personal information we hold, where it comes from, how and why it is processed and if and to whom it is disclosed.
• Policies & Procedures - revised data protection policies and procedures to meet the requirements and standards of the GDPR and any relevant data protection laws, including: -
• Data Protection – our main policy and procedure document for data protection has been overhauled to meet the standards and requirements of the GDPR. Accountability and governance measures are in place to ensure that we understand and adequately disseminate and evidence ourobligations and responsibilities; with a dedicated focus on privacy by design and the rights of individuals.
• Data Retention & Erasure, we have updated our retention policy and schedule to insure that we meet the ‘data minimisation’ and ‘storage limitation’ principles and that personal information is stored, archived and destroyed compliantly and ethically. We have dedicated erasure procedures in place to meet the new ‘Right to Erasure’ bligation and are aware of when this and other data subject’s rights apply; along with any exemptions, response timeframes and notification responsibilities.
• Data Breaches – our breach procedures ensure that we have safeguards and measures in place to identify, assess, investigate and report any personal data breach at the earliest possible time. Our procedures are robust and have been disseminated to all employees, making them aware of the reporting lines and steps to follow.
• International Data Transfers & Third-Party Disclosures – where Altscale stores or transfers personal information outside the EU, we have robust procedures and safeguarding measures in place to secure, encrypt and maintain the integrity of the data. Our procedures include a continual review of the countries with sufficient adequacy decisions, as well as provisions for binding corporate rules; standard data protection clauses or approved codes of conduct for those countries without. We carry out strict due diligence checks with all recipients of personal data to assess and verify that they have appropriate safeguards in place to protect the information, ensure enforceable data subject rights and have effective legal remedies for data subjects where applicable.
• Subject Access Request (SAR) – we have revised our SAR procedures to accommodate the revised 30-day timeframe for providing the requested information and for making this provision free of charge. Our new procedures detail how to verify the data subject, what steps to take for processing an access request, what exemptions apply and a suite of response templates to ensure that communications with data subjects are compliant, consistent and adequate.
• Legal Basis for Processing - we are reviewing all processing activities to identify the legal basis for processing and ensuring that each basis is appropriate for the activity it relates to. Where applicable, we also maintain records of our processing activities, ensuring that our obligations under Article 30 of the GDPR and Schedule 1 of the Data Protection Bill are met.
• Privacy Notice/Policy – we have revised our Privacy Notice(s) to comply with the GDPR, ensuring that all individuals whose personal information we process have been informed of why we need it, how it is used, what their rights are, who the information is disclosed to and what safeguarding measures are in place to protect their information.
• Obtaining Consent - we have revised our consent mechanisms for obtaining personal data, ensuring that individuals understand what they are providing, whyand how we use it and giving clear, defined ways to consent to us processing their information. We have developed stringent processes for recording consent, making sure that we can evidence an affirmative opt-in, along with time and date records; and an easy to see and access way to withdraw consent at any time.
• Direct Marketing - we have revised the wording and processes for direct marketing, including clear opt-in mechanisms for marketing subscriptions; a clear notice and method for opting out and providing unsubscribe features on all subsequent marketing materials.

    Data Subject Rights

    In addition to the policies and procedures mentioned above that ensure individuals can enforce their data protection rights, we provide easy to access information via our website of an individual’s right to access any personal information that Altscale processes about them and to request information about: 

• What personal data we hold about them
• The purposes of the processing
• The categories of personal data concerned
• The recipients to whom the personal data has/will be disclosed
• How long we intend to store your personal data for
• The right to have incomplete or inaccurate data about them corrected or completed and the process for requesting this
• The right to request erasure of personal data ( where applicable ) or to restrict processing in accordance with data protection laws, as well as to object to any direct marketing from us and to be informed about any automated decision-making that we use

   Information Security & Technical and Organisational Measures

    Altscale takes the privacy and security of individuals and their personal information very seriously and take every reasonable measure and precaution to protect and secure the personal data that we process. We have robust information security policies and procedures in place to protect personal information from unauthorised access, alteration, disclosure or destruction and have several layers of security measures, including: SSL, access controls, password policy, encryptions, pseudonymisation, practices, restriction, IT, authentication.

What information do we collect and how will we use it

    Retention period for personal data

    Except as otherwise mentioned in this privacy notice, we keep your personal information only for as long as required by us:

• to provide you with the services you have requested;
• to comply with other laws, including for the period demanded by tax authorities (this will typically be a period of 7 years);
• to support a claim or defence in court.

    If you have not purchased or otherwise used any of our services, your personal information may be deleted by deleting your account.

    If you have any questions about our preparation for the GDPR, please contact data privacy team at gdpr@altscale.com

  Web Visit

    You may visit our Websites in any of the following ways:

• By using your browser to navigate to our Websites including (but not limited to) www.Altscale.com; www.AltScale.net; www.AltScale.bg.
• By viewing an advertisement displayed on a third party website that is served content by our web server;
• By viewing an email that is served content by our or a third party web server.

    When you visit our Website, our server logs your IP address (unique network addresses), the time and duration of your visit, and the time and duration of the pages on our website you view. If you arrive at our website by clicking a paid advertisement (including a paid search engine result) or a link in an email, then we will capture information that tracks your visit from that link. If you arrive at our Website by clicking a non-paid source, such as link in a non-paid search engine result or an unsponsored link on another website, we may capture information that tracks your visit from that source, to the extent we are able to do so. We may also capture information about your computer system, such as your browser type and operating system.

    We will likely place a cookie on your hard drive during the web visit. A cookie is a unique alphanumeric identifier that we use to help us identify the number of unique visitors to our Website, whether or not those visitors are repeat visitors, and the source of the visits. Cookies cannot be executed as code or used to deliver a virus. Other servers cannot read them and personal information cannot be gathered from them. They are simply an identifier shared between you and us to allow us to improve the services we offer to you through our Website. If you do not wish cookies to be placed on your computer, then they can be disabled in your web browser. The option to do so is normally found in your browser's "security settings" section. However, please note, permanently disabling cookies in your browser may hinder your use of our Website as well as other websites and interactive services.

    A web beacon, also known as a web bug, is a small graphic (usually 1 pixel x 1 pixel), that is embedded in a web advertisement, email, or page on our web site, but is invisible to you. When you view a page on our web site, an email or an advertisement your web browser will request the web beacon from a web server, which in turn will set a cookie in your web browser containing a unique identifier. This unique identifier will be linked to log information that is used to track your movements on our web site in order to determine the effectiveness of content and advertising campaigns.

    We do not collect personal information about you as part of a web visit, but web visit information may be tied to other information (including personal information) we collect from you via chat, web forms, and the other means we describe in this Privacy Statement.

    Our advertising agencies may also use web beacons and cookies to track your activity on our website originating from the advertisement. However, we will not provide your personal information to our advertising agencies. Our advertising agencies maintain their own privacy policies, and you should also review those.