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Please see [[Configuring Privacy, Confidentiality and Other Policies]] for related information.
This article describes which features and policies [[SmartSimple]] has implemented into our platform to help you comply with the GDPR.
For more information about SmartSimple's implementation of GDPR-compliance, see [https://www.smartsimple.com/gdpr.html our website].
=Feature Descriptions and Requirements=
SmartSimple has created two categories of features that are GDPR-compliant: features related to '''Personal Data Management, '''and those related to '''Consent and Compliance. '''
==Personal Data Management Features==
'''Personal Data Management '''features are focused on managing your data effectively and automating your data governance model. To make the most use of the following features, we recommend identifying all personal data fields in the system and organizing them into data categories.
!|Feature
!|Description
!|GDPR RegulationRequirements
|-
||'''Personal Data Field (Information & Access)'''
When the user displays ''any page ''in the system that uses '''personal information fields, '''they have the ability to see all of the explanations that you have added. On their [[Profile|profile]], the user can view a list of personal data fields that you hold on them.
<pre>This feature is automatically available in every instance of SmartSimple. </pre>
||
* Informed consent
* Data subject's right to transparent information
* Information to be provided where data is collected from the data subject
* Right of access
|-
||'''[[Configuring Privacy, Confidentiality and Other Policies#Policy Details|Policy Consent]]'''
||
After establishing a policy internally, you can enforce it by having your [[User|users]] agree to it upon [[Login Page|login]]. The policy can be set to mandatory, ensuring that if a user does not accept the policy, they will not be able to access the system or enter personal information.
||
* [https://gdpr-info.eu/art-7-gdpr/ (7)(1)] informed consent, demonstration of consent
* [https://gdpr-info.eu/art-2-gdpr/ (2)] Accountability
|-
||'''[[Login Page#Agreeing to Cookies|Cookie Policy]]'''
||
Cookie Policy is a feature to alert users to the use of cookies on the [[SmartSimple]] application. It will alert [[User|users]] landing on the [[Login Page|login page]] and require them to accept the use of cookies.
We have also introduced a policy template that you can use to create your own cookie usage policy within your [[Login Page#Privacy and Security Policies|Privacy and Security Policies]].
||
* Informed consent
|-
||'''Personal Data Erasure'''
||
The '''personal data erasure '''is used in order to comply with requests to delete user data. This new feature can be enabled on [[UTA]] {{L2}} [[Types|types]] as an individual's data erasure request.
Within this {{L2}}, an [[Global User Administrator|administrator]] would then be able to review these Level 2 requests and have an option available that would delete the user [[Profile|profile]] of the Level 2 owner.
A certificate of data erasure is then created in order to reference this activity.
||
* Rights of the data subject
|-
||'''Request Tracker UTA'''
||
<pre>This is a customized feature that must be requested by the client to be configured into their specific instance of SmartSimple. </pre>
We are able to build a Request Tracker {{UTA}} to help you manage Data Subject Requests, such as the following: Right of Access; Right to Rectification; Right to Erasure; Right to Restriction of Processing, etc.
||
* Obligations of the controller
* Rights of the data subject
|}
=Glossary for GDPR=
{| class="wikitable"
|-
!|Term, Principle, or Abbreviation
!|Definition
|-
||'''EEA'''
||
''European Economic Area - ''based on an international agreement in 1992, the EEA enables the extension of the European Union's single market to non-EU member parties. Membership has grown to 31 states as of 2016: 28 EU member states, as well as three of the four member states of the European Free Trade Association: Iceland, Liechtenstein, and Norway. The agreement is applied provisionally with respect to Croatia. Switzerland has not yet joined the EEA, but has a series of bilateral agreements with the EU which allow it to also participate in the internal market.
|-
||'''EU'''
||
''European Union'' - a political and economic union of 28 member states that are located primarily in Europe.
|-
||'''GDPR'''
||
''General Data Protection Regulation - ''The GDPR 2016/679 is a regulation in EU Law on data protection and privacy for all individual citizens of the European Union (EU) and the European Economic Area (EEA). The GDPR was adopted on April 14, 2016 and became enforceable beginning May 25, 2018.
|}
{| class="wikitable"
|-
!|GDPR Principle
!|Description
|-
||'''(5)(1)(b) Purpose Limitation'''
||
'''Article 5 '''of GDPR: Principles relating to processing of personal data
1. Personal data shall be:
b) collected for spescific, 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, scientific, or historical research purposes or statistical purposes shall, in accordance with Article 89(1), not be considered to be incompatible with the initial purposes ('purpose limitation')
|-
||'''(5)(1)(e) Storage Limitation'''
||
'''Article 5 '''of GDPR: Principles relating to processing of personal data
1. Personal data shall be:
e) 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
|-
||'''(5)(1)(f) Integrity and Confidentiality '''
||
'''Article 5 '''of GDPR: Principles relating to processing of personal data
1. Personal data shall be:
f) 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 ('integrity and confidentiality')
|-
||'''(5)(2) Accountability '''
||
'''Article 5 '''of GDPR: Principles relating to processing of personal data
2. The controller shall be responsible for, and be able to demonstrate compliance with, [https://gdpr-info.eu/art-5-gdpr/ paragraph 1] ('accountability')
|-
||'''(7)(1) Informed consent, demonstration of consent'''
||
'''Article 7''' of GDPR: Conditions for consent
1. Where processing is based on consent, the controller shall be able to demonstrate that the data subject has consented to the processing of his or her personal data.
|-
||'''(25)(2) Technical and organisational measures - purpose'''
||
'''Article 25 '''of GDPR: Data protection by design and by default
2. The controller shall implement appropriate technical and organisational measures for ensuring that, by default, only personal data which are necessary for each specific purpose of processing are processed.
2. The controller shall implement appropriate technical and organisational measures for ensuring that, by default, only personal data which are necessary for each specific purpose of processing are processed.
That obligation applies to:
* the amount of personal data collected
* the extent of their processing
* the period of their shortage
* their accessibility
In particular, such measures shall ensure that by default personal data are not made accessible without the individual's intervention to an indefinite number of natural persons.
|-
||'''(30)(1)(e) Categories of Personal Data'''
||
'''Article 30 '''of GDPR: Records of processing activities
1. Each controller and, where applicable, the controller's representative, shall maintain a record of processing activities under its responsibility. That record shall contain all of the following information:
e) where applicable, transfers of personal data to a third country or an international organisation, including the identification of that third country or international organisation and, in the case of transfers referred to in the second subparagraph of Article 49(1), the documentation of suitable safeguards
|-
||'''(89)(1) Safeguards and Pseudonymization '''
||
'''Article 89 '''of GDPR: Safeguards and derogations relating to process for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes
1. <sup>1</sup> Processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes, shall be subject to appropriate safeguards, in accordance with this Regulation, for the rights and freedoms of the data subject.
<sup>2</sup> Those safeguards shall ensure that technical and organisational measures are in place in particular in order to ensure respect for the principle of data minimisation.
<sup>3</sup> Those measure may include ''pseudonymization ''provided that those purposes can be fulfilled in that manner.
<sup>4</sup> Where those purposes can be fulfilled by further processing which does not permit or no longer permits the identification of data subjects, those purposes shall be fulfilled in that manner.
|}
=Support for Privacy Policies and Features=
If you have any inquiries about the GDPR, the implementation of any of these features, and/or [[SmartSimple]]'s [[Privacy Policy|privacy policies]], please feel free to reach out to us via our [[How the SmartSimple Support Desk Works|support team]].
=See Also=
* [[Configuring Privacy, Confidentiality and Other Policies]]
