General policy for the protection of personal data

Respect for privacy and the protection of personal data constitutes a factor of trust, a value to which DBWO is particularly attached, by attaching importance to respecting the fundamental freedoms and rights of each individual.

This personal data protection policy demonstrates the commitments implemented by DBWO in the context of its daily activities for the responsible use of personal data.

A Data Protection Officer (DPO)

In order to preserve the privacy and protection of everyone's personal data, DBWO appointed, in 2020, a Data Protection Officer (DPO) who carries out his duties for all of its structures.

The Data Protection Officer is a trusted representative. A specialist in the protection of personal data, responsible for ensuring the preservation of privacy and the proper application of personal data protection rules, the primary contact for the French National Commission for Information Technology and Civil Liberties (CNIL) and all persons concerned by the collection or processing of personal data.

To contact our Data Protection Officer:

[email protected]

DBWO is the publisher of the Viqtor® platform.

This “Compliance as a Service” platform is a software suite aimed at facilitating the deployment and monitoring of organizations’ compliance with the General Data Protection Regulation.

Personal data processed by DBWO

As part of its recruitment policyt, DBWO receives requests accompanied by CVs or even completed with personal data allowing the creation of a job interview file communicated by candidates, which will be kept for two years after receipt unless hired or requested by the person concerned.

In the context of the execution of the employment contracts of its employees or the service contracts of its individual service providers DBWO processes personal data necessary for the organization of their mission or its legal obligations (civil status data, financial data, data relating to personal life, diplomas and authorizations, communication data, etc.). The data is kept throughout the contractual relationship and extended for some of it due to legal or tax requirements.   

As part of its commercial efforts exclusively for professionals in its sector, DBWO is also required to process personal data such as Name, First name, Company, Position, Telephone number, Email address that it obtains directly during exchanges at trade fairs or events, requests expressed to its services or via its website by prospects, or indirectly from companies specializing in the creation of sectorized professional databases. The processing of this data is based partly on legitimate interest (request for information, exchange of contact details) for another part on consent. The person concerned can at any time request the deletion of their data.

In the context of the execution of its contracts, DBWO processes the personal data of contacts and correspondents designated by its clients or subcontractors and retains this data (surname, first name, email address, telephone number, position, company) throughout the contractual relationship unless it receives instructions from the Company to delete the contact from its databases.

Principles applicable to the protection of personal data

DBWO applies the principles defined by Privacy by Design in all its projects and implements a policy of informing and raising awareness among its teams regarding compliance with the principles set out in the General Data Protection Regulation.

It offers its customers software compatible with all the requirements of the General Data Protection Regulation.

1. Specific, explicit and legitimate purpose of the processing:

When personal data is collected, it is collected for specific objectives (purposes) defined by the processing needs of our customers.

2. Proportion and relevance of data collected:

The personal data collected is strictly necessary for the purpose of the collection. The design of the DBWO Software strives to minimize the data collected.

3. Limited retention period of personal data:

Personal data when hosted under the responsibility of DBWO is kept for a limited period which does not exceed the period necessary for the purposes of collection.

4. Confidentiality / Data Security: 

Information Systems Protection Policies (PSSI) are implemented, adapted to the nature of the data processed and their processing.

Appropriate physical, logical and organizational security measures are in place to ensure the confidentiality of data, including preventing unauthorized access.

DBWO also requires any subcontractor to provide appropriate safeguards to ensure the security and confidentiality of personal data.

5. Rights of individuals:

With regard to processing carried out under the responsibility of DBWO

• • All necessary means to guarantee the effectiveness of individuals' rights over their personal data are implemented.

• • Personal data is collected fairly; no collection is carried out without the knowledge of individuals or without their being informed.

• • The personal data collected is brought to the attention of the persons concerned.

• • The data collected is not subsequently used in a manner incompatible with these purposes.

• • Personal data is kept accurate and up to date.

• • Data retention periods are brought to the attention of individuals and vary depending on the nature of the data, the purpose of the processing, or legal or regulatory requirements.

• • If personal data were to be transferred to countries located in the European Union or outside the European Union, the persons concerned would be specifically informed, and specific measures would be taken to regulate these transfers.

• • The means necessary to guarantee the effectiveness of the rights of individuals over their personal data are implemented, in particular through clear and complete information on the data processing implemented, easily accessible and understandable by all.

• • Everyone has rights over their personal data, which they can exercise at any time and free of charge, by providing proof of their identity. Individuals can therefore access their personal data and, in certain cases, have it rectified, deleted, or object to its processing.

With regard to processing carried out under the responsibility of users of the DBWO software

• • DBWO raises awareness and trains all of its employees who come into contact with private data as part of maintenance operations on the principles set out by the GDPR.

• • DBWO informs users of its software about the essential rules determining the legality of processing private data.

• • DBWO informs users of its software about the precautions required to protect the personal data collected.

• • The DBWO software provides tools for protecting this data (logging, pseudonymization, encryption, etc.)

• • Access to these rights (access, rectification, deletion, opposition) is facilitated by the functionalities of the software used by DBWO.
    
    

6. Rights arising from the Law for a Digital Republic.

The new Article 40-1 of the Data Protection Act allows individuals to give instructions relating to the retention, deletion and communication of their data after their death.

A person may be designated to carry out these instructions. This person then has the authority, when the person is deceased, to take cognizance of the instructions and request their implementation from the data controllers concerned.

In the absence of instructions given by the person during his lifetime, the heirs will have the possibility of exercising certain rights, in particular:

• • The right of access, if necessary for the settlement of the deceased's estate;

• • The right to object to the closure of the deceased's user accounts and to the processing of their data.

Monitoring of the Personal Data Protection Policy.

This policy is updated regularly to take into account legislative and regulatory developments, and any changes in the organization of DBWO or in the offers, products and services proposed.