Last revised on November 12, 2018; effective as of May 24, 2018
What is the GDPR?
The General Data Protection Regulation (GDPR), is a European privacy law that will go into effect on May 25th 2018. It is based upon the European understanding that privacy is a fundamental human right. Established by the EU Parliament, the GDPR regulates how individuals and organizations can obtain, use, store, and remove personal data. It gives EU citizens and residents control over their personal data and simplifies the regulatory environment for international business that takes place in the EU. If you’re curious, you can read the full text of the law here.
What is personal data?
The GDPR defines personal data as any information that can be used to directly or indirectly identify a person, such as a name, photograph, email address, or even an IP address.
What are the requirements of the GDPR?
The Data Protection Principles include the following requirements:
- Personal data must be processed in a fair, legal, and transparent way. It should only be used in a way that a person would reasonably expect.
- Personal data should only be collected to fulfill a specific purpose, and it should only be used for that purpose. Organizations must specify why they need personal data when they collect it.
- Personal data should be held no longer than necessary to fulfill its purpose.
- People covered by the GDPR have the right to access their own personal data. They can also request a copy of their data and request that their data be updated, deleted, restricted, or transported to another organization.
Why is it important?
GDPR adds new requirements regarding how companies should protect the personal data they collect and process. It also raises the stakes for compliance by increasing enforcement and imposing greater fines for breach. Beyond these facts, it’s simply the right thing to do. At 9to5 we respect your data privacy and we have solid security and privacy practices in place that go beyond the requirements of this new regulation.
9to5’s commitment to GDPR Compliance and data privacy
Here is an overview of how 9to5 has prepared to meet the new regulatory requirements.
Data Processing Addendum
Upon request, we offer a data processing addendum (DPA) for our customers who collect data from people in the EU. Our DPA offers contractual terms that meet GDPR requirements and that reflect our data privacy and security commitments to our customers.
To guarantee no terms are imposed on us beyond what is reflected in our DPA and Terms of Service, we cannot agree to sign individual customers’ DPAs. We are a small team and are unable to make individual changes to our DPA. Any changes to the standard DPA would require legal counsel and considerable back and forth discussion, which would be cost-prohibitive for our small team.
If you have any questions or concerns, please let us know.
Training and awareness
We formed a core team of leaders from each area of 9to5’s business. The representatives in this group ensure that 9to5 covers the requirements of GDPR, across all teams. 9to5 requires that all employees learn about and follow GDPR regulations, and ensures that all employees participate in the necessary training.
Updates to our third party vendor contracts
We reviewed the 3rd party vendors that we use to provide our products and services, and we performed a comprehensive review of their GDPR compliance. We already have DPAs in place with the vendors who offer a signed version, while others have a DPA that is automatically accepted as part of the Terms of Service on May 25th.
Individual Data Subject’s Rights – Data Access, Portability, and Deletion
Risk Assessment (data protection impact assessments)
One of the GDPR requirements is a managed data protection impact assessment (DPIA) process. A DPIA process is a way to help us identify and minimize the data protection risks of a project. The 9to5 engineering team has always undergone security and privacy due diligence when choosing tools and making implementation decisions, so this requirement is easy for us. Any time we introduce a change to the way we handle personal data, we discuss the potential impact on 9to5 customers and explore possible privacy and security risks to personal data. If any risk is identified, no matter how small, our product and engineering teams collaborate on a solution to mitigate the data privacy and security risk to anyone who interacts with the 9to5 platform. We will continue to execute this risk assessment process as we expand 9to5’s offerings.
We updated our existing breach management and communication plan to comply with the GDPR regulations concerning the escalation process and requirements for data subject notification.
We are here for you
We are working with our customers to answer any questions and address any concerns regarding how we protect their personal data. If you have any questions, please don’t hesitate to reach out.