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PRIVACY POLICY


1. INTRODUCTION

 

In its everyday business operations Intentifty Demand makes use of a variety of
data about identifiable individuals, including data about:

 

 * Business professionals
 * Current, past and prospective employees
 * Customers
 * Users of its websites
 * Subscribers
 * Other stakeholders

 

In collecting and using this data, the organisation is subject to a variety of
legislation controlling how such activities may be carried out and the
safeguards that must be put in place to protect it.

 

The purpose of this policy is to set out the relevant legislation and to
describe the steps Intentifty Demand is taking to ensure that it complies with
it.

 

This control applies to all systems, people and processes that constitute the
organisation’s information systems, including board members, directors,
employees, suppliers and other third parties who have access to Intentifty
Demand systems.

 

The following policies and procedures are relevant to this document:

 

 * Data Protection Impact Assessment Procedure
 * Legitimate Interest Assessment Procedure
 * Information Security Incident Response Procedure
 * Records Retention and Protection Policy

 


 

 


2  DATA PROTECTION POLICY

 


2.1   THE GENERAL DATA PROTECTION REGULATION

 

The General Data Protection Regulation 2016 (GDPR) is one of the most
significant pieces of legislation affecting the way that Intentifty Demand
carries out its information processing activities. Significant fines are
applicable if a breach is deemed to have occurred under the GDPR, which is
designed to protect the personal data of citizens of the European Union. It is
Intentifty Demand’s policy to ensure that our compliance with the GDPR and other
relevant legislation is clear and demonstrable at all times.

 


2.2  DEFINITIONS

 

There are a total of 26 definitions listed within the GDPR and it is not
appropriate to reproduce them all here. However, the most fundamental
definitions with respect to this policy are as follows:

 

Personal data is defined as:

 

any information relating to an identified or identifiable natural person (‘data
subject’); an identifiable natural person is one who can be identified, directly
or indirectly, in particular by reference to an identifier such as a name, an
identification number, location data, an online identifier or to one or more
factors specific to the physical, physiological, genetic, mental, economic,
cultural or social identity of that natural person;

 

‘processing’ means:

 

any operation or set of operations which is performed on personal data or on
sets of personal data, whether or not by automated means, such as collection,
recording, organisation, structuring, storage, adaptation or alteration,
retrieval, consultation, use, disclosure by transmission, dissemination or
otherwise making available, alignment or combination, restriction, erasure or
destruction;

 

‘controller’ means:

 

the natural or legal person, public authority, agency or other body which, alone
or jointly with others, determines the purposes and means of the processing of
personal data; where the purposes and means of such processing are determined by
Union or Member State law, the controller or the specific criteria for its
nomination may be provided for by Union or Member State law;

 

 

 

 


2.3   PRINCIPLES RELATING TO PROCESSING OF PERSONAL DATA

 

There are a number of fundamental principles upon which the GDPR is based.

 

These are as follows:

 

 1. Personal data shall be:

 

(a) processed lawfully, fairly and in a transparent manner in relation to the
data subject (‘lawfulness, fairness and transparency’);

 

(b) collected for specified, explicit and legitimate purposes and not further
processed in a manner that is incompatible with those purposes; further
processing for archiving purposes in the public interest, scientific or
historical research purposes or statistical purposes shall, in accordance with
Article 89(1), not be considered to be incompatible with the initial purposes
(‘purpose limitation’);

 

(c) adequate, relevant and limited to what is necessary in relation to the
purposes for which they are processed (‘data minimisation’);

 

(d) accurate and, where necessary, kept up to date; every reasonable step must
be taken to ensure that personal data that are inaccurate, having regard to the
purposes for which they are processed, are erased or rectified without delay
(‘accuracy’);

 

(e) kept in a form which permits identification of data subjects for no longer
than is necessary for the purposes for which the personal data are processed;
personal data may be stored for longer periods insofar as the personal data will
be processed solely for archiving purposes in the public interest, scientific or
historical research purposes or statistical purposes in accordance with Article
89(1) subject to implementation of the appropriate technical and organisational
measures required by this Regulation in order to safeguard the rights and
freedoms of the data subject (‘storage limitation’);

 

(f) processed in a manner that ensures appropriate security of the personal
data, including protection against unauthorised or unlawful processing and
against accidental loss, destruction or damage, using appropriate technical or
organisational measures (‘integrity and confidentiality’).

 

 2. The controller shall be responsible for, and be able to demonstrate
    compliance with, paragraph 1 (‘accountability’).

 

 

Intentifty Demand will ensure that it complies with all of these principles both
in the processing it currently carries out and as part of the introduction of
new methods of processing such as new IT systems.

 

 

 


2.4  RIGHTS OF THE INDIVIDUAL

 

The data subject also has rights under the GDPR. These consist of:

 

 1. The right to be informed
 2. The right of access
 3. The right to rectification
 4. The right to erasure
 5. The right to restrict processing
 6. The right to data portability
 7. The right to object
 8. Rights in relation to automated decision making and profiling.

 

Each of these rights are supported by appropriate procedures within Intentifty
Demand that allow the required action to be taken within the timescales stated
in the GDPR.

 

These timescales are shown in Table 1.

 

Data Subject Request

Timescale

The right to be informed

When data is collected (if supplied by data subject) or within one month (if not
supplied by data subject)

The right of access

One month

The right to rectification

One month

The right to erasure

Without undue delay

The right to restrict processing

Without undue delay

The right to data portability

One month

The right to object

On receipt of objection

Rights in relation to automated decision making and profiling.

Not specified

 

Table 1 - Timescales for data subject requests

 


2.5  LAWFULNESS OF PROCESSING

 

There are six alternative ways in which the lawfulness of a specific case of
processing of personal data may be established under the GDPR. It is Intentifty
Demand policy to identify the appropriate basis for processing and to document
it, in accordance with the Regulation. The options are described in brief in the
following sections.

 


2.5.1   CONSENT

 

Unless it is necessary for a reason allowable in the GDPR, Intentifty Demand
will always obtain explicit consent from a data subject to collect and process
their data. In case of children below the age of 16 (a lower age may be
allowable in specific EU member states) parental consent will be obtained.
Transparent information about our usage of their personal data will be provided
to data subjects at the time that consent is obtained and their rights with
regard to their data explained, such as the right to withdraw consent. This
information will be provided in an accessible form, written in clear language
and free of charge.

 

If the personal data are not obtained directly from the data subject then this
information will be provided to the data subject within a reasonable period
after the data are obtained and definitely within one month.

 


2.5.2   PERFORMANCE OF A CONTRACT

 

Where the personal data collected and processed are required to fulfil a
contract with the data subject, explicit consent is not required. This will
often be the case where the contract cannot be completed without the personal
data in question e.g. a delivery cannot be made without an address to deliver
to.

 


2.5.3  LEGAL OBLIGATION

 

If the personal data is required to be collected and processed in order to
comply with the law, then explicit consent is not required. This may be the case
for some data related to employment and taxation for example, and for many areas
addressed by the public sector.

 


2.5.4  VITAL INTERESTS OF THE DATA SUBJECT

 

In a case where the personal data are required to protect the vital interests of
the data subject or of another natural person, then this may be used as the
lawful basis of the processing. Intentifty Demand will retain reasonable,
documented evidence that this is the case, whenever this reason is used as the
lawful basis of the processing of personal data. As an example, this may be used
in aspects of social care, particularly in the public sector.

 


2.5.5   TASK CARRIED OUT IN THE PUBLIC INTEREST

 

Where Intentifty Demand needs to perform a task that it believes is in the
public interest or as part of an official duty then the data subject’s consent
will not be requested. The assessment of the public interest or official duty
will be documented and made available as evidence where required.

 


2.5.6  LEGITIMATE INTERESTS

 

If the processing of specific personal data is in the legitimate interests of
Intentifty Demand and is judged not to affect the rights and freedoms of the
data subject in a significant way, then this may be defined as the lawful reason
for the processing. Again, the reasoning behind this view will be documented.

 


2.6  PRIVACY BY DESIGN

 

Intentifty Demand has adopted the principle of privacy by design and will ensure
that the definition and planning of all new or significantly changed systems
that collect or process personal data will be subject to due consideration of
privacy issues, including the completion of one or more data protection impact
assessments.

 

The data protection impact assessment will include:

 

 * Consideration of how personal data will be processed and for what purposes
 * Assessment of whether the proposed processing of personal data is both
   necessary and proportionate to the purpose(s)
 * Assessment of the risks to individuals in processing the personal data
 * What controls are necessary to address the identified risks and demonstrate
   compliance with legislation

 

Use of techniques such as data minimization and pseudonymisation will be
considered where applicable and appropriate.

 


2.7  CONTRACTS INVOLVING THE PROCESSING OF PERSONAL DATA

 

Intentifty Demand will ensure that all relationships it enters into that involve
the processing of personal data are subject to a documented contract that
includes the specific information and terms required by the GDPR.

 


2.8  INTERNATIONAL TRANSFERS OF PERSONAL DATA

 

Transfers of personal data outside the European Union will be carefully reviewed
prior to the transfer taking place to ensure that they fall within the limits
imposed by the GDPR. This depends partly on the European Commission’s judgement
as to the adequacy of the safeguards for personal data applicable in the
receiving country and this may change over time.

 

 


2.9   DATA PROTECTION OFFICER

 

A defined role of Data Protection Officer (DPO) is required under the GDPR if an
organisation is a public authority, if it performs large scale monitoring or if
it processes particularly sensitive types of data on a large scale. The DPO is
required to have an appropriate level of knowledge and can either be an in-house
resource or outsourced to an appropriate service provider.

 

Please contact privacy@intentifydemand.com for more info here.

 


2.10  BREACH NOTIFICATION

 

It is Intentifty Demand’s policy to be fair and proportionate when considering
the actions to be taken to inform affected parties regarding breaches of
personal data. In line with the GDPR, where a breach is known to have occurred
which is likely to result in a risk to the rights and freedoms of individuals,
the relevant supervisory authority will be informed within 72 hours. This will
be managed in accordance with our Information Security Incident Response
Procedure which sets out the overall process of handling information security
incidents.

 

 


2.11   ADDRESSING COMPLIANCE TO THE GDPR

 

The following actions are undertaken to ensure that Intentifty Demand complies
at all times with the accountability principle of the GDPR:

 

 * The legal basis for processing personal data is clear and unambiguous
 * A Data Protection Officer is appointed with specific responsibility for data
   protection in the organisation (if required)
 * All staff involved in handling personal data understand their
   responsibilities for following good data protection practice
 * Training in data protection has been provided to all staff
 * Rules regarding consent are followed
 * Routes are available to data subjects wishing to exercise their rights
   regarding personal data and such enquiries are handled effectively
 * Regular reviews of procedures involving personal data are carried out
 * Privacy by design is adopted for all new or changed systems and processes
 * The following documentation of processing activities is recorded:
   * Organisation name and relevant details
   * Purposes of the personal data processing
   * Categories of individuals and personal data processed
   * Categories of personal data recipients
   * Agreements and mechanisms for transfers of personal data to non-EU
     countries including details of controls in place
   * Personal data retention schedules
   * Relevant technical and organisational controls in place

 

These actions are reviewed on a regular basis as part of the management process
concerned with data protection.

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