On May 25, 2018, the European Union (the “EU”) implemented a new data privacy and protection regulation, called the General Data Protection Regulation (the “GDPR”). This regulation aims to standardize data protection laws across the EU and also lay down standards to be observed worldwide while processing of personal data originating in the EU; The GDPR also has a strong emphasis on affording individuals stronger, more consistent rights to access and control their personal information.
At Constellation Consulting Group (“Constellation”), we take compliance of data privacy and security regulations very seriously. For GDPR, we are working diligently to ensure that we are compliant with the rules laid out by the law. In the following sections, we have outlined our approach to comply with the GDPR.
Constellation GDPR Compliance
Constellation is a provider of services which includes advisory, implementation, training and support for enterprise performance management, data & analytics, customer experience and robotic process automation solutions.
Our services and website are used and explored by our clients (existing and prospective), we at Constellation process certain amount of personal information of our clients (existing and prospective) in the capacity of a Data Controller (for any personal information submitted on the website) and in the capacity of a Data Processor (for any personal information provided by our clients when they use our services).
We have performed a company-wide information discovery exercise to identify and assess what personal information we hold, where it comes from, how and why it is processed, and to whom it is disclosed.
Data Subject Consent
As a Data Controller, Constellation has updated its Privacy Policies, Cookies Policy and Disclaimer for the usage of the Cookies in as per the requirements of GDPR on its website http://www.constellation-cg.com and it requires all the visitors, users of its website to provide consent for use of personal information. Constellation also allows such users to exercise their rights in relation to their personal information such as modification, rectification, deletion of their data.
As a Data Controller we execute contracts required under the GDPR with our data processor to ensure that the data processor process the personal information as per the GDPR. Additionally, we implement technical and organizational security measures to ensure compliances.
As a Data Processor we comply with the required safeguards pertaining to safety of personal information received from our clients.
Data Subject Rights & Transfer of Data Outside EU
Constellation has in place an article 28 GDPR-compliant data processing addendum including the EU Model Clauses to ensure an appropriate legal basis for data transfers outside the EU.
Data Retention & Erasure
We have formulated an internal data protection compliance policy that includes the data retention schedule to ensure that we comply with the ‘data minimization’ and ‘storage limitation’ and other such principles under the GDPR and that personal information is stored, archived, and destroyed in accordance with the GDPR.
Record Keeping as per the GDPR
According to Article 30 of the GDPR, each processor and controller’s representative needs to maintain a record of all activities pertaining to the processing of personal information in such an organization. Constellation maintains such records as required under Article 30(1) and Article 30(2) of the GDPR
Data Breach and Mitigation Process
The GDPR has stipulated measures and notifications that must be made upon discovery of a data security breach. Constellation has put in place internal measures to minimize the risk of any data security breach happening. However, in the unlikely event of any such breach happening, Constellation intends to honour its responsibilities as laid down under the GDPR, which includes notifying in a timely manner, its customers, and the supervisory authorities.
Constellation Promise on GDPR
At Constellation, maintaining the security, integrity, safety and confidentiality of personal data in our possession is of the highest priority. Constellation has already taken adequate measures to ensure that we fulfil our promise of being fully compliant with GDPR. In case you have any queries, please feel free to reach us at firstname.lastname@example.org.