Introduction
In 2016, the EU adopted General Data Protection Regulation (“GDPR”). The GDPR is now recognized as law across the EU. GDPR enforcement begins on 25th May 2018.
Our Commitment
Siber Systems Inc. (‘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 recognize our obligations in continuously updating and expanding this program to keep meet the demands of the GDPR.
Siber Systems Inc. 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 details of GDPR compliance have been summarised in this statement and include the development and implementation of data protection roles, policies, procedures, controls and measures to ensure maximum and ongoing compliance.
How We Have Prepared for the GDPR
Siber Systems Inc. has a consistent level of data protection and security across our organization, that fully complies with all DGPR provisions.
Our preparations included:
- Completed Information Audit – we have identified that we DO NOT store any sensitive personal data as it is defined by GDPR. We only store non-sensitive personal data that is required to conduct business. We have identified what personal information we hold, where it comes from, how and why it is processed and if and to whom it is disclosed, as well as GDPR compliance of downstream data processors.
- Revised Policies & Procedures – we have revised our 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 our obligations 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 ensure that we meet the ‘data minimization’ and ‘storage limitation’ principles and that personal information is stored, archived and destroyed compliantly and ethically. We have procedures in place to meet the ‘Right to Access’ (Article 15), ‘Right to Rectification’(Article 16), ‘Right to Erasure’ (Article 17) obligation 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 Siber Systems Inc. collects, transfers and stores on US servers ONLY personal information needed for execution of the contract between the client and the Company. 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.
- Legal Basis for Processing – our processing activities are in compliance with the Article 6.
- Records of Processing Activities – Siber Systems Inc. is excluded from the obligation to maintain records of our processing activities, under Article 30 due to size and nature of data conditions.
- Privacy Notice/Policy – our Privacy Policies (separate for each product family) comply with the GDPR.
- Data Protection Impact Assessments (DPIA) – we neither process sensitive personal information nor perform large-scale processing of non-sensitive personal information. We have developed stringent procedures and assessment templates for carrying out impact assessments that comply fully with the GDPR’s Article 35 requirements. We have implemented documentation processes that record each assessment, allow us to rate the risk posed by the processing activity and implement mitigating measures to reduce the risk posed to the data subject(s).
- Processor Agreements – where we use any third-party to process personal information on our behalf (i.e. Payment Processing), we have ensured that Processor Agreements and due diligence procedures are in place for ensuring that they (as well as we), meet and understand their/our GDPR obligations. These measures include initial and ongoing reviews of the service provided, the necessity of the processing activity, the technical and organizational measures in place and compliance with the GDPR.
- Special Categories Data – we have identified that we do not process any of the special categories of the personal data.
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 email gdpr@siber.com of an individual’s right to access any personal information that Siber Systems Inc. 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
- For how long we intend to store your personal data
- If we did not collect the data directly from them, information about the source
- 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
- The right to lodge a complaint or seek judicial remedy and who to contact in such instances
Information Security & Technical and Organizational Measures
Siber Systems Inc. takes the privacy and security of individuals and their personal information very seriously and takes 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 unauthorized access, alteration, disclosure or destruction and have several layers of security measures, including employee training, data encryption in transit, data encryption in storage, password policy, one-time-password and two-factor authentication mechanisms, as well as other technical and organizational prevention, detective, and correction controls.
GDPR Roles and Employees
Siber Systems Inc. have appointed a data privacy team to constantly monitor compliance with the GDPR legislation. The team are responsible for promoting awareness of the GDPR across the organization, assessing our GDPR readiness, identifying any potential gap areas and implementing the new policies, procedures and corrective measures.
Siber Systems Inc. understands that continuous employee awareness and understanding is vital to the continued compliance of the GDPR and have involved our employees in our preparation plans. We have implemented an employee training program specific to the which have been provided to all employees, and forms part of our induction and annual training program.
If you have any questions or requests related to GDPR, please contact our GDPR compliance team via email gdpr@siber.com.