Data Protection Policy
Good Digital Hygiene for Startups
Erasmus+ Project nr. 2022-1-LV01-KA220-VET-000086725
1. Data protection principles
The Organisation is committed to processing data in accordance with its responsibilities under the Data Processing Agreement (DPA).
DPA requires that personal data shall be:
- processed lawfully, fairly and in a transparent manner in relation to individuals;
- 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 not be considered to be incompatible with the initial purposes;
- adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
- 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;
- 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 subject to implementation of the appropriate technical and organisational measures required by the DPA in order to safeguard the rights and freedoms of individuals; and
- 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.”
2. Lawful, fair and transparent processing
To ensure its processing of data is lawful, fair and transparent, the process shall be reviewed along the duration of the project
Individuals have the right to access their personal data and any such requests made to the Organisation shall be dealt with in a timely manner.
3. Lawful purposes
All data processed by the Organisation must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests.
Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data.
Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent should be clearly available and systems should be in place to ensure such revocation is reflected accurately in the Organisation’s systems.
4. Data minimisation
The Organisation shall ensure that personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
The Organisation shall take reasonable steps to ensure personal data is accurate.
Where necessary for the lawful basis on which data is processed, steps shall be put in place to ensure that personal data is kept up to date.
6. Archiving / removal
To ensure that personal data is kept for no longer than necessary, the Organisation shall put in place an archiving policy. Personal data is stored for the entire duration of the project implementation.
The archiving policy shall consider what data should/ must be retained, for how long, and why.
The Organisation shall ensure that personal data is stored securely using modern software that is kept-up-to-date.
Access to personal data shall be limited to personnel who need access and appropriate security should be in place to avoid unauthorised sharing of information.
When personal data is deleted this should be done safely such that the data is irrecoverable.
Appropriate back-up and disaster recovery solutions shall be in place.
In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data, the Organisation shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach to responsible authorities.
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10. Google Analytics
The information generated by cookies, about how you use the website (browser type, operating system used, reference URL (from where you arrived at the site / the last site used), anonymized IP and time) are stored in Google servers. For the website the IP anonymization function is set in Google Analytics, which means that access to the entire IP address you use is blocked.
The data is used by Google to analyze how you use this website and to generate a report about the activity on the website, to which we have access. You can prevent the use of this data through the cookie settings, the browser settings you use or by installing the Google Analytics Opt-out Browser Add-on.
11. Your rights
You have the right to be informed about how your data is used. Through this document we inform you about how your data is used in this website.
If you have any questions or concerns about our policies or your privacy, please do not hesitate to contact us. You can reach us via email at email@example.com, or through our website contact form.
Thank you for visiting our website and for your cooperation in adhering to our policies and guidelines.