Data Protection

Supplier Data Protection Obligation

ESCP Business School and AGORA Student Union require all suppliers to commit to the protection of customer personal data. Suppliers are obligated to process personal data in accordance with GDPR and other relevant data protection laws. This includes implementing appropriate security measures, ensuring data is processed lawfully, and respecting the rights of data subjects.

 

Data Protection Principles

GEP, registered at the trade company register of GEP Communication Group AB under the number 556612-0928 is committed to processing data in accordance with its responsibilities under the DPA.

Personal data can be defined as all information that can be directly or indirectly attributed to the customer of the ESCP Boutique hosted by GEP. Examples of personal data are name, address, e-mail address, telephone number, payment information and purchase order.

DPA requires that personal data shall be:

  1. processed lawfully, fairly and in a transparent manner in relation to individuals;
  2. 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 or statistical purposes shall not be considered to be incompatible with the initial purposes;
  3. adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
  4. 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;
  5. 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 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
  6. 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.

 

General Provisions

  1. The designated Data Protection Officer (DPO) is responsible for ensuring compliance with this policy.
  2. The policy will be reviewed annually, and GEP is registered with the relevant Data Protection Authority.
  3. The different categories of data collected and processed by GEP are mostly hosted in the European Union.
  4. GEP takes all the necessary measures to ensure the security of the data hosted outside the European Union like signing standard contractual clauses for the transfer of personal data to third countries pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council.

 

Lawful Purposes

  1. Data processing must be based on consent, contract, legal obligation, vital interests, public task, or legitimate interests.
  2. Consent must be explicit and revocable, with systems in place to reflect revocation accurately.
  3. Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data.
  4. Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent should be available and systems should be in place to ensure such revocation is reflected accurately in the GEP’s systems.

 

Data Minimisation

  1. Personal data will be adequate, relevant, and limited to what is necessary for processing purposes.
  2. Specific considerations will be made for the University's systems to ensure minimization.

 

Accuracy

  1. GEP will take reasonable steps to ensure data accuracy and keep it up-to-date as per the lawful basis of processing.

 

Archiving / Removal

  1. To ensure that personal data is kept for no longer than necessary, GEP shall put in place an archiving policy for each area in which personal data is processed and review this process annually.
  2. The archiving policy shall consider what data should/must be retained, for how long, and why.

 

Security

  1. GEP shall ensure that personal data is stored securely using modern software that is kept-up-to-date.
  2. 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.
  3. When personal data is deleted this should be done safely such that the data is irrecoverable.
  4. Appropriate back-up and disaster recovery solutions shall be in place.

 

Breach Protocol

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 the ICO.