GENERAL DATA PROTECTION REGULATION AND NEWELO
Newelo Oy
Hämeenkatu 10
33100 Tampere, Finland
company ID 2332618-5
INTRODUCTION
General Data Protection Regulation (GDPR) is a regulation that strengthens and unifies data protection for all individuals within the European Union (EU). The regulation covers all the processing of personal data within the EU. This documents describes how Newelo complies with GDPR regulation.
DATA PROTECTION OFFICER
Newelo has appointed a data protection officer who acts as a contact person for GDPR related issues. The data protection officer operates with the highest level of confidentiality and reports to Newelo board of directors.
CONFIDENTIALITY AND ACCOUNTABILITY
Newelo processes follow the principles of GDPR. Newelo processes all the data with strict confidentiality. Newelo is entitled for demonstrate the compliance of GDPR to audits and inspections conducted by the data controller or the national authority.
CUSTOMER CONSENT
The business contract between Newelo and the its customer company act as a consent for Newelo to process the data owned by the data processor (customer).
NEWELO AS DATA PROCESSOR
Newelo executes data processing on behalf of the data controller. Newelo limits the number of persons accessible to data, and all the processing is carried out with the most confidentiality. Data processing is monitored and stored into log files.
Newelo is authorised to delete or return the data to the data controller if such is requested unless some of data is to be stored according to the national or European Union law. Newelo uses merely data centres within EU area.
NEWELO AS DATA CONTROLLER
Newelo acts a data controller via the contracts of employment between Newelo and its employees. Newelo stores employee information for a required period of time determined by the national law. Newelo uses an accounting firm for its administrative functions.
Newelo uses a CRM database and spreadsheet documents containing contact information of companies and their contact persons for the support of business-to-business sales function in the company.
RIGHT TO ACCESS
The data subject has a right to obtain confirmation whether Newelo has personal data being processed. If such personal data exist, Newelo as a data controller will provide the copy of the personal data describing the purpose and categories, and the possible third party recipients of the data. Acting as a data processor Newelo does not hand over any data belonging to its customers.
RIGHT TO RECTIFY
The data subject has a right to rectify to incorrect or incomplete data, which Newelo as a data controller will execute without undue delay.
RIGHT TO ERASURE
The data subject has a right to obtain the erasure of personal data, which Newelo as a data controller will execute without undue delay.
DATA PORTABILITY
The data subject has a right to transfer her data to a new service provider. Newelo as a data controller will deliver a copy of the personal information in a digital format to a new service provider.
PERSONAL DATA BREACH
In case of a possible data breach affecting the personal data Newelo is to inform the national supervisory authority within 72 hours after having become aware of the incident.
DATA MINIMISATION AND PSEUDONYMISATION
Newelo only processes data owned by the data controller (customer) that is relevant for execution of the tasks agreed in the business contract. Newelo only stores data that is necessary for the tasks, and the data is stored temporarily for a limited period of time. Persons having access to the data is limited with corresponding access rights required for the job.
In case of archiving and data warehousing Newelo will make the data anonymous, which removes the identifying data from the data subjects.
DATA SECURITY
Unauthorised persons have no access to Newelo premises. The entrances to Newelo premises are monitored with camera surveillance. The server room is kept locked, and the access is restricted to authorised personnel. Logging into computer systems are subject to user accounts, and the usage of systems is tracked. All the guests visiting Newelo premises will sign the guest book, and a responsible host is assigned to look after the guests.
NEWELO RIGHTS TO CHANGE THIS PRIVACY DOCUMENT
Newelo strives to continuously develop services and provides a better customer experience. As a result, new services and functions may appear. Newelo will update this report if needed. Legislative changes may also require Newelo to modify or refine parts of this report.