GDPR COMPLIANCE STATEMENT — POLICY
The EU General Data Protection Regulation (“GDPR”) came into force on 25 May 2018.
The new Regulation aims to standardize data protection laws and processing across the EU, giving people greater rights to access and control their personal information.
Ballable OÜ (“we” or “us” or “our”), a company registered in Estonia with registered number 16539801. Our trading and registered office address is at Harju maakond, Tallinn, Kesklinna linnaosa, Ahtri tn 12, 10151, Estonia.
We are committed to ensuring protection of all personal information that we hold, and to provide and to protect all such data. We have always had a robust and effective data protection programme in place which complies with existing law and abides by the data protection principles. We recognise our obligations in updating and expanding this program to meet the requirements of GDPR.
We are dedicated to safeguarding the personal information under our control and in maintaining a system that meets our obligations under the new regulations. Our practice is summarized below in this statement including the development and implementation of new data protection roles, policies, procedures, controls and measures to ensure maximum and ongoing compliance.
How We are Prepared for GDPR
We already have a consistent level of data protection and security across our organization, but we have introduced new measures to ensure compliance.
- Information Audit — we carried out an audit of information previously held and ensured that it was compliant with the new regulations.
- Policies and Procedures — we have revised data protection policies and procedures to meet the requirements and standards of the GDPR and any relevant data protection laws, including:
- Legal Basis for Processing - we have reviewed all processing activities to identify the legal basis for processing and ensured that each basis is appropriate for the activity it relates to. Where applicable, we also maintain records of our processing activities, ensuring that our obligations under Article 30 of the GDPR are met.
- Data Protection - our main policy and procedure document for data protection has been revised 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 and the rights of individuals.
- Data Retention and Erasure - we have updated our retention policy and schedule to ensure that we meet the "data minimisation" and "storage limitation" principles and that personal information is stored, archived and destroyed in accordance with our obligations. We have procedures in place to meet the new "Right to Erasure" obligation.
- Data Breaches - our procedures ensure that we have safeguards in place to identify, assess, investigate and report any personal data breach as early as possible. Our procedures have been explained to all employees.
- International Data Transfers and Third-Party Disclosures - where Ballable stores or transfers personal information outside the EU, we have robust procedures in place to secure the integrity of the data. Our procedures include a continual review of the countries with sufficient adequacy decisions, as well as binding rules, or standard data protection clauses for those countries without.
- Subject Access Request (SAR) - we have revised our SAR procedures to accommodate the revised 30-day timeframe for providing the requested information and for making this provision free of charge.
- Special Categories Data - where we obtain and process any special category information, we do so in complete compliance with the Article 9 requirements and have high-level encryptions and protections on all such data. Special category data is only processed where necessary and is only processed where we have first identified the appropriate Article 9(2) basis. Where we rely on consent for processing, this is explicit and is verified by a signature, with the right to modify or remove consent being clearly signposted.
- Privacy Notice/Policy - we have revised our Privacy Notice(s) to comply with the GDPR, ensuring that all individuals whose personal information we process have been informed of why we need it, how it is used, what their rights are, who the information is disclosed to and what safeguarding measures are in place to protect their information.
- Obtaining Consent - we have revised our consent mechanisms for obtaining personal data, ensuring that individuals understand what they are providing, why and how we use it and giving clear, defined ways to consent to us processing their information.
- Direct Marketing - we have revised the wording and processes for direct marketing, including clear opt-in mechanisms for marketing subscriptions; a clear notice and method for opting out and providing unsubscribe features on all subsequent marketing materials.
- Data Protection Impact Assessments (DPIA) - where we process personal information that is considered high risk, we have developed stringent procedures 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. Payroll, Recruitment, Hosting, etc.), we have drafted compliant Processor Agreements and due diligence procedures for ensuring that they meet and understand their/our GDPR obligations.
Data Subject Rights
We provide easy-to-access information via [our website, in the office, during induction, etc.] of an individual’s right to access any personal information that we process 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
- how long we intend to store your personal data for
- 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.
Ballable OÜ takes the privacy and security of individuals and their personal information very seriously and takes every reasonable measure 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.
GDPR Roles and Employees
Ballable OÜ has designated Leandro Gravina as our Data Protection Officer (DPO) and have appointed a data privacy team to develop and implement our roadmap for complying with the new data protection Regulation. The team is responsible for promoting awareness of the GDPR across the organization, assessing our GDPR compliance, identifying any gap areas and implementing the new policies, procedures and measures.
Ballable understands that continuous employee awareness and understanding is vital to the continued compliance of the GDPR and has involved our employees in our preparation plans.
If you have any questions about our GDPR compliance policies, please contact us by: