At BeyondTrust, we are committed to ensuring the security and protection of the personal information that we process, and to provide a compliant and consistent approach to data protection. We have always had a robust and effective data protection program in place which complies with existing law and abides by the data protection principles. However, we recognise our obligations in updating and expanding this program to meet the demands of the GDPR and similar regulations.
We are dedicated to safeguarding the personal information under our remit and in developing a data protection regime that is effective, fit for purpose and demonstrates an understanding of, and appreciation for the new Regulation. Our preparation and objectives for GDPR compliance have been summarised in this statement and include the development and implementation of new data protection roles, policies, procedures, controls and measures to ensure maximum and ongoing compliance.
How We Address GDPR Requirements:
Our ongoing compliance efforts include:
* Information Audit – Periodically carrying out a company-wide information audit to identify and assess what personal information we hold, where it comes from, how and why it is processed and if and to whom it is disclosed.
* Policies & Procedures – Revising and implementing new 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 review our processing activities to identify the legal basis for processing and ensuring 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 and Schedule 1 of the Data Protection Bill are met.
* Privacy Notice/Policy – we 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 updated 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. We developed stringent processes for recording consent, making sure that we can evidence an affirmative opt-in, along with time and date records; and an easy to see and access way to withdraw consent at any time.
* Direct Marketing - we 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, involves large scale processing or includes special category/criminal conviction data; we have developed stringent procedures and assessment templates 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 compliant Processor Agreements and due diligence procedures for ensuring that they (as well as we), meet and understand their/our GDPR obligations. These measures include initial and ongoing reviews of the service provided, the necessity of the processing activity, the technical and organisational measures in place and compliance with the GDPR.
* Data Protection – our main policy and procedure document for data protection has been overhauled 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 by design and the rights of individuals.
* Data Retention & 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 compliantly and ethically. We have dedicated erasure procedures in place to meet the new ‘Right to Erasure’ obligation and are aware of when this and other data subject’s rights apply; along with any exemptions, response timeframes and notification responsibilities.
* Data Breaches – our breach procedures ensure that we have safeguards and measures in place to identify, assess, investigate and report any personal data breach at the earliest possible time. Our procedures are robust and have been disseminated to all employees, making them aware of the reporting lines and steps to follow.
* International Data Transfers & Third-Party Disclosures – where BeyondTrust stores or transfers personal information outside the EU, we have robust procedures and safeguarding measures in place to secure, encrypt and maintain the integrity of the data. Our procedures include a continual review of the countries with sufficient adequacy decisions, as well as standard data protection clauses or approved codes of conduct for those countries without. We carry out strict due diligence checks with all recipients of personal data to assess and verify that they have appropriate safeguards in place to protect the information, ensure enforceable data subject rights and have effective legal remedies for data subjects where applicable.
* Subject Access Request (SAR) – we have revised our SAR procedures to accommodate the revised timeframe for providing the requested information. Our new procedures detail how to verify the data subject, what steps to take for processing an access request, what exemptions apply and a suite of response templates to ensure that communications with data subjects are compliant, consistent and adequate.
* 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 or the Data Protection Bill Schedule 1 condition. 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.
Data Subject Rights
In addition to the policies and procedures mentioned above that ensure individuals can enforce their data protection rights, we provide easy to access information of an individual’s right to access any personal information that BeyondTrust processes 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
Information Security & Technical and Organisational Measures
BeyondTrust takes the privacy and security of individuals and their personal information very seriously and takes reasonable measures and precautions 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 unauthorised access, alteration, disclosure or destruction and have several layers of security measures, including:
* BeyondTrust utilizes secure communications, HTTPS/SSL, for web-based communications and data collection
* BeyondTrust products are configurable to meet data transmission and data at rest requirements
* Access Controls:
* BeyondTrust has implemented an access control authentication approach based on need to know and separation of duties
* BeyondTrust products are configurable to meet strict access controls and audit requirements for privileged and general users, and can be integrated into federated identity and access management solutions
* Password Policies:
* BeyondTrust adheres to a strict, complex password policy utilizing multi-factor authentication
* BeyondTrust products are configuration to meet password complexity, periodicity, and versioning requirements, and can be integrated into federated identity and access management solutions
* BeyondTrust collects only the minimum data needed to conduct business.
* BeyondTrust has applied pseudonymisation in data collection to support metric collection and analysis efforts.
GDPR Roles and Employees
BeyondTrust has a designated Data Protection Officer (DPO) and a GDPR Representative, and has 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 organisation, assessing our GDPR readiness, identifying any gap areas and implementing the new policies, procedures and measures.
BeyondTrust understands that continuous employee awareness and understanding is vital to the continued compliance of the GDPR. We have implemented an employee training program ongoing data and privacy protection.
If you have any questions about our preparation for the GDPR, please contact our Data Protection Officer (DPO) and GDPR Representative at firstname.lastname@example.org.
BeyondTrust Personal Data Request
Below are instructions on how to request that BeyondTrust supply you with a copy of any personal data we hold about you or to make corrections of such data. The information you supply in making this request will only be used for the purposes of identifying the personal data you are requesting and responding to your request.
We will respond promptly to the following:
- Our receipt of your written request; or
- Our receipt of any further information we may ask you to provide to enable us to comply with your request.
Please send your request to the following address:
Attn: Data Protection Officer
11695 Johns Creek Parkway, Suite 200,
Johns Creek, Georgia 30097
In order for us to properly process your request, please provide us the following information in your written request.
(1) Contact Information
Full Legal Name
(2) Verify Contact Information
To ensure we are releasing data to the right person we require you to provide us with proof of your identity and of your address.
If we are not satisfied you are who you claim to be, we reserve the right to refuse to grant your request.
(3) Please let us know what action you would like us to take:
- (a) Provide you a copy of the information we hold about you and instruct us where to send it.
- (b) Erase the data we hold about you (subject to the applicable law).
- (c) Rectify certain data about you (please explain specifically the changes requested).
While in most cases we will be happy to accommodate your requests, we nevertheless reserve the right, in accordance with applicable law to charge a fee or refuse the request if it is considered to be “manifestly unfounded or excessive.” However, we will make every effort to provide you with a satisfactory form of access or summary of information if suitable.
For additional information on Beyond Trust’s privacy policies see www.beyondtrust.com/privacy