Privacy and data protection policy
Definitions
GDPR
Means the General Data Protection Regulation.
Data Protection Officer
The individual responsible for the ongoing compliance with this policy at Reos Partners Global Inc. is Ana Paula Borges Pinho.
Register of systems
Means a register of all systems or contexts in which personal data is processed by the Reos Partners Global Inc.
Personal data
Means any information relating to an identified / identifiable individual, whether it relates to his or her private, professional, or public life. This can be anything from a name, photo, email address, bank details, medical information, IP address, or a combination of the data that directly or indirectly identifies the person.
1. Data protection principles
Reos Partners Global Inc. is committed to processing data in accordance with its responsibilities under the GDPR.
Article 5 of the GDPR 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 providers 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 GDPR 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. General provisions
- This policy applies to all personal data processed by Reos Partners Global Inc..
- The Data Protection Officer shall take responsibility for the Reos Partners Global Inc.’s ongoing compliance with this policy.
- This policy shall be reviewed at least annually.
- This policy and related Register of Systems is complemented by Staff Guidelines for Data Management for Reos Partners Global Inc.
3. Lawful, fair and transparent processing
- To ensure its processing of data is lawful, fair and transparent, Reos Partners Global Inc. shall establish and maintain a Register of Systems.
- The Register of Systems shall be reviewed at least annually.
- Individuals have the right to access their personal data or request that it be deleted and any such requests made to Reos Partners Global Inc, shall be dealt with within 30 days.
4. Lawful purposes
- All processing of data by Reos Partners Global Inc. must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests.
- Reos Partners Global Inc. shall note the appropriate lawful basis in the Register of Systems.
- 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 will always be clearly available and systems will be in place to ensure such revocation is reflected accurately in Reos Partners Global Inc.’s systems.
5. Data minimisation
- Reos Partners Global Inc. shall ensure that personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
6. Accuracy
- Reos Partners Global Inc. 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.
7. Archiving / removal
- To ensure that personal data is kept for no longer than necessary, Reos Partners Global Inc. shall put in place an archiving policy for each area in which personal data is processed and review this process annually.
- The archiving policy shall consider what data should/must be retained, for how long, and why.
8. Security
- Reos Partners Global Inc. 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.
- When personal data is deleted this shall be done safely such that the data is irrecoverable.
- Appropriate back-up and disaster recovery solutions shall be in place.
- When data provided is sensitive or entails a security risk, Reos Partners Global Inc. will take extra measures to encrypt, secure, and avoid storing information and may develop additional specific policies and protocols.
9. Providing data to third parties
- For the purpose of executing our work, Reos Partners will sometimes provide personal data to third-party service providers.
- Data providers will be informed when data may be shared with these third-parties.
- Reos Partners will review the data protection policies of these third parties to ensure that personal data will not be used or disclosed for any other than the expressed purpose.
10. Breach
- 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, Reos Partners Global Inc. shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach to the following bodies in Massachusetts, which are the supervisory authorities for data for Reos Partners Global Inc.:
- The Massachusetts Attorney General’s Office;
- The Massachusetts Office of Consumer Affairs and Business Regulation; and
- The affected data providers
11. Minors
- Reos Partners does not knowingly collect data or personal information from anyone under the age of 16 unless we receive the explicit consent of their parent or guardian.
- Should it be discovered that a person under 16 years of age has provided personal information without your consent, Reos Partners will delete the data provided.
END OF POLICY