Privacy policy

SUB-ALLIANCE data protection regulations
Date 25/05/2018 Version 2.0


This Privacy Policy sets out how SUB-ALLIANCE collects, stores, uses, discloses, shares and transfers your information.
PLEASE READ THIS PRIVACY STATEMENT CAREFULLY AS IT CONSTITUTES ACCEPTANCE OF THIS PRIVACY POLICY AND THE COLLECTION, STORAGE, USE, DISTRIBUTION, SHARING AND TRANSFER OF YOUR DATA IN ACCORDANCE WITH IT. WE MAY AMEND THIS PRIVACY POLICY AT ANY TIME IF ANY OF THE PROVISIONS HEREOF ARE FOUND TO BE INCOMPLETE OR OBSOLETE AND THERE IS SUFFICIENT INTEREST IN SUCH AMENDMENTS. IF WE MAKE MATERIAL CHANGES TO THIS PRIVACY POLICY, WE WILL POST A NEW VERSION OF THE POLICY ON THE WEBSITE, EFFECTIVE IMMEDIATELY.
Introduction


This document is intended to provide a concise statement of the rules concerning the data protection obligations of SUB-ALLIANCE. This includes obligations in the processing of personal data to ensure that the company complies with the requirements of the relevant legislation, namely the GDPR. https://www.eugdpr.org/ Rationale SUB-ALLIANCE must comply with the Data Protection principles set out in the relevant legislation. These Rules apply to all Personal Data collected, processed and stored by SUB-ALLIANCE concerning its service providers, customers and staff in the course of its business. Scope of application The rules concern both personal data and sensitive personal information of the persons concerned. The rules apply equally to manually held personal data and to data held in automated form. SUB-ALLIANCE will treat both personal data and sensitive personal information with equal care. Both categories are hereinafter referred to as "Personal Data" in these rules unless otherwise stated. The Data Retention and Destruction Policy, the Data Retention Period List and the Data Loss Notification Procedure. SUB-ALLIANCE as Data Controller In the course of its daily activities, the company SUB-ALLIANCE obtains, processes and stores personal data concerning: - Its staff - Its customers - Third party suppliers of raw materials and services who collaborate with it. In accordance with the RGPD, these must be obtained and managed fairly. It is impossible to require all staff to be experts in Data Protection legislation. However, SUB-ALLIANCE is committed to ensuring that its staff have sufficient knowledge of the legislation to be able to anticipate and identify Data Protection issues, where appropriate. In such circumstances, staff should inform the Data Protection Officer to ensure that appropriate remedial action is taken. These Rules provide guidelines governing the procedure to be followed if a SUB-ALLIANCE staff member is unsure whether data may be disclosed. In general, the staff member should consult the Data Protection Officer for clarification. Data Subject Access Requests Any formal written request from a Data Subject requesting a copy of their personal data (Data Subject Access Request) will be forwarded, as soon as possible, to the Data Protection Officer and will be dealt with as soon as possible in accordance with the GDPR. In complying with these guidelines, SUB-ALLIANCE will adhere to good practice regarding applicable Data Protection legislation. Data Protection Principles The following key principles are enshrined in the GDPR and are fundamental to the SUB-ALLIANCE Data Protection Regulations. In its capacity as Data Controller, SUB-ALLIANCE ensures that all data :

1.

...will be obtained and processed fairly and lawfully. In order to ensure that data are obtained fairly, at the time of collection the data subject shall be informed of - The identity of the data controller. - Of the objectives for which the data are collected - Of the persons to whom the data can be disclosed by the Person in charge of the treatment - Of any other information necessary so that the treatment can be fair. SUB-ALLIANCE will fulfil this obligation as follows: - Wherever possible, the informed consent of the Data Subject will be sought prior to the processing of his/her data. - If this is not possible, SUB-ALLIANCE will verify that the collection of the data is justified in accordance with one of the other lawful conditions for processing, i.e. legal obligation, contractual necessity, etc. - The processing of personal data will only be carried out within the framework of the legal activities of SUB-ALLIANCE; the latter will protect the rights and freedoms of the Data Subject.

2.

...will be collected for specific and legitimate purposes. SUB-ALLIANCE will obtain data for specified, lawful and clearly stated purposes. A Data Subject will be entitled to question the purposes for which SUB-ALLIANCE holds his or her data; SUB-ALLIANCE will be able to state them clearly.

3.

...will not be further processed in a way incompatible with the purposes determined. Any use of the data by SUB-ALLIANCE will be compatible with the purposes for which they were obtained.

4.

...will be treated in such a way as to guarantee their security. SUB-ALLIANCE will use high standards of security to protect the personal data entrusted to it. Appropriate security measures will be taken to protect all personal data held by SUB-ALLIANCE in its capacity as Data Controller from unauthorised access or from alteration, destruction or disclosure. 3 Only duly authorised staff members will be able to access and manage staff and client files.

5.

...will be accurate, complete and, where necessary, kept up to date. SUB-ALLIANCE will: - verify that administrative and computer validation processes are implemented to regularly assess the accuracy of the data; - conduct regular reviews and audits to ensure that the relevant data is accurate and kept up-to-date - conduct regular assessments to determine whether to retain certain Personal Data.

6.

...will be adequate, relevant and limited to what is necessary for the purposes for which it is collected and processed. SUB-ALLIANCE will verify that the data it processes with respect to Data Subjects is relevant to the purposes for which it was collected. Data that is not relevant will not be acquired or retained.

7.

...will not be retained for longer than is necessary to fulfill the purposes identified. Once the retention period has expired, SUB-ALLIANCE undertakes to destroy, erase or otherwise render the data unusable. Data They include the automated and manual data. Automated data means data stored on a computer or stored with the intention of processing it in a computer. Manual data means data processed as part of an appropriate file or stored with the intention of adding it to an appropriate file. Personal Data Information relating to a natural person, who can be identified either directly from such data or indirectly in connection with other data that can be legitimately obtained by the Data Controller. (In case of doubt, SUB-ALLIANCE refers to the definition of the Article 29 Working Party and updates it as necessary). Sensitive Personal Information A special category of Personal Data relating to: racial or ethnic origin, political opinions, religious, ideological or philosophical beliefs, trade union membership, mental or physical health, sexual orientation, commission of an offence or crime and conviction for a criminal offence. Controller A person or entity who, alone or together with others, controls the content and use of Personal Data by determining the purposes for which and the means by which they are processed. Data Subject A natural person who is affected by the Personal Data, i.e. to whom the data relates directly or indirectly. Subcontractor A person or entity who processes Personal Data on behalf of a Controller on the basis of a formal contract, but who is not an employee of the Controller; he or she processes the Data in the course of his or her work. Appropriate file Any set of information about natural persons that is not processed by automated equipment (computers) and that is structured, either by reference to individuals or by reference to criteria relating to individuals, in such a way that specific information about an individual is readily retrievable.

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