DLA Piper’s Article 28 GDPR working group produced this “Example Data Protection Addendum Addressing Article 28 GDPR (Processor Terms) and Incorporating Standard Contractual Clauses for Controller to Processor Transfers of Personal Data from the … It's also worth considering the definition of personal data. If we took the broadest definition possible, writing down someone's name could constitute as recording their personal data. It’s important to note here that companies that process “special categories of data” (like racial or ethnic origin, political opinions, religious or philosophical beliefs, genetic data, and more) cannot rely on Legitimate Interest as a lawful basis for processing such data. In business terms, a consultation is usually a meeting held to discuss a particular topic. 11. For example, personal data includes information regarding a person's name, date of birth, home address, email address, IP address, geolocation, as well as sensitive personal information such as medical records and sexual orientation. An alternative definition of recording is to record a person's voice and what was said by them. This information was obtained directly from the individual as opposed to being obtained from a third party. This definition means that the GDPR is likely to apply to any business or organization that does anything involving personal information. • where is the processing taking place? to have a lawful basis for each and every instance of data processing. Identify what a lawful basis for personal data processing in your particular case is. Notably, the GDPR applies to any business or organization that controls or processes the data of EU citizens, even if the company has no physical presence within the EU. 'Personal data’ means any information relating to an identified or identifiable natural person. •who are you disclosing the data to? The DPA and GDPR contain rights concerning the processing of personal data which is held in either a computerised format as part of a database or manual records forming part of a relevant filing system. For example, you may record a person's name and state that you have their consent to collect certain types of personal data from them. During the sales process, a customer may request more information or sign up for a trial, which may require the processing of personal data like credit card information or contact information. Under the GDPR, individuals have the right to be informed as to which lawful basis an organization has for processing their data, which means organizations are required to provide the data subject with a privacy notice that includes the lawful basis they are using for processing. We will go over what “personal data” is according to the GDPR. Ideally, all digitally stored data should be encrypted for security purposes. Arranging client's data in a specific structure to enable you to analyse it and look for patterns. Personal data is any information that relates to an identified or identifiable living individual. The organization may need to process the data subject’s information in order to collect payment. Data processors are required to abide by the instructions of Data Controllers unless these instructions conflict with the GDPR itself. Quick and easy way to secure our company website. The data protection policy doesn’t need to provide specific details on how the organisation will meet the Regulation’s data protection principles, as these will be covered in the organisation’s procedures. What is GDPR. It demands that the records need to be in writing, including in the electronic form. The GDPR considers market research activities under the umbrella of Legitimate Interest as long as processing will never affect a data subject negatively and the purpose of data processing is a “reasonable expectation” for service (for example, if the market research will allow a company to provide its customers with a better, more personalized customer experience). This category is similar to the organization of data and neither term is defined in the regulation. Scenario One: Direct Marketing and Fraud Prevention. By Focal Point Insights. Processing which does not require identification. Make sure your processing is done according to the principles and requirements outlined in Article 5. For example, if you only need a person's email address to enter them into a prize drawing, it would not be right to ask the individual to disclose their full name, sexual orientation or date or birth as this information is not relevant for your purposes. Some activities may fall into several. This is regardless of whether your company deals directly with personal data, or whether your company provides a third party service to another company whereby you process data for them. Little Green Sheep – straight to it Personal data are any information which are related to an identified or identifiable natural person. The right to data portability introduced by Article 20 of the GDPR is one that does not have an equivalent in the Data Protection Directive that it replaces. All rights reserved. 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