Back-ups | The Processor maintains the ability to restore the availability and access to the Personal Data in a timely manner in the event of a physical or technical incident affecting the Processing of the Personal Data. This includes use of the following measures:
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Portable devices | The Processor maintains a process for ensuring the integrity and security of portable devices. This includes use of the following measures:
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Notion Encryption policy | The Processor maintains a process for ensuring that personal data is pseudonymised and encrypted as appropriate. This includes ensuring that all portable devices are encrypted and use of the following measures:
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Firewalls and anti-virus | The Processor maintains a process for ensuring that appropriate firewalls and anti virus systems are in place. This includes use of the following measures:
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Systems selection | The Processor maintains a process for ensuring the ongoing confidentiality, integrity, availability and resilience of processing systems and services associated with the Processing of the Personal Data. This includes use of the following measures:
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Personnel vetting | The Processor maintains a process for ensuring that its personnel accessing the Protected Data are vetted to ensure their reliability and integrity. This includes use of the following measures:
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Independent testing including (penetrating testing and vulnerability scanning) | The Processor maintains a process for regular testing, assessment and evaluation of the security measures required by this Agreement. This includes use of the following measures:
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Asset register | The Processor maintains a process for ensuring that the location of all its IT assets are known at all times. This includes use of an internal asset register which logs the location and ownership of all portable assets. |
Passwords, tokens | The Processor maintains a process for ensuring appropriate passwords and tokens are used to access its systems. This includes use of the following measures:
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VPN | The Processor maintains a process for ensuring the security of its internal network. This includes use of the following measures:
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Actions log | The Processor maintains a process for logging all interactions with the Protected Data. This includes the following measures:
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SSL | The Processor maintains appropriate Secure Socket Layer technology to protect its systems and applications. |
Permissions | The Processor maintains a permissions based process for using the Personal Data only for the purpose(s) prescribed by Client and not any other purposes and for making the Personal Data available to staff strictly on a 'need to know' basis and procuring that all staff members to whom it discloses Personal Data are made aware that the Personal Data is Confidential Information and subject to the obligations set out in this Agreement. |
Data Minimisation | The Processor maintains a process for copying, reproducing or distributing Personal Data only to the extent necessary to enable the discharge of obligations under this Agreement and for no other purpose. The Processor minimises, to the fullest extent possible, the disclosure of Personal Data to third parties, such disclosure to be strictly as is necessary to enable the Processor to discharge its obligations to Client. |
Confidentiality | The Processor maintains a process for treating and safeguarding the Personal Data as strictly private and confidential and taking all steps necessary to preserve such confidentiality. This includes use of appropriate contract terms used with staff and contractors handling such data. |
Breach Handling: | The Processor maintains a process for informing Clients, as soon as reasonably practical, if the Processor becomes aware of or suspects that a Personal Data Breach has occurred. This policy is available upon request. |
Training and Monitoring: | The Processor maintains a process for ensuring that all staff and Sub-Processors comply with this Agreement. This includes use of periodic GDPR training and compliance reviews as part of staff appraisals. |