Share your CV
RU

Techno Diasoft LLC policy on personal data processing

GENERAL TERMS


The Policy of personal data processing (hereinafter referred to as the Policy) is developed in accordance with the Federal Law dated 27.07.2006. No. 152-FZ "On Personal Data" (hereinafter referred to as the Law).


This Policy defines the procedure for processing personal data and measures to ensure the security of personal data at Techno Diasoft LLC (hereinafter referred to as the Operator) in order to protect the rights and freedoms of individuals and citizens in the processing of their personal data, including the protection of the right to privacy, personal and family secrecy.


The following basic concepts are used in the Policy:

  • automated processing of personal data - processing of personal data by means of computer equipment;
  • blocking of personal data - temporary cessation of personal data processing (except for cases when processing is necessary to clarify personal data);
  • personal data information system - a set of personal data contained in databases and information technologies and technical means ensuring their processing;
  • depersonalization of personal data - actions as a result of which it is impossible to determine, without using additional information, whether personal data belong to a particular subject of personal data;
  • processing of personal data - any action (operation) or set of actions (operations) performed with or without the use of automation means with personal data, including collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data;
  • operator - a state authority, municipal authority, legal entity or individual, independently or jointly with other persons organizing and (or) carrying out processing of personal data, as well as determining the purposes of personal data processing, composition of personal data subject to processing, actions (operations) performed with personal data;
  • personal data - any information relating to a directly or indirectly defined or identifiable natural person (subject of personal data);
  • provision of personal data - actions aimed at disclosure of personal data to a certain person or a certain circle of persons;
  • dissemination of personal data - actions aimed at disclosure of personal data to an indefinite number of persons (transfer of personal data) or familiarization of personal data to an unlimited number of persons, including disclosure of personal data in mass media, placement in information and telecommunication networks or providing access to personal data in any other way;
  • cross-border transfer of personal data - transfer of personal data to the territory of a foreign country to a foreign governmental authority, a foreign individual or a foreign legal entity;
  • destruction of personal data - actions as a result of which it is impossible to restore the content of personal data in the information system of personal data and (or) as a result of which material carriers of personal data are destroyed.

Techno Diasoft LLC is obliged to publish or otherwise provide unrestricted access to this Personal Data Processing Policy in accordance with part 2 of Article 18.1 of the Law.


PRINCIPLES AND CONDITIONS OF PERSONAL DATA PROCESSING


2.1. Principles of personal data processing

Processing of personal data by the Operator is carried out on the basis of the following principles:

  • lawfulness and fair basis;
  • limiting the processing of personal data to the achievement of specific, predetermined and legitimate purposes;
  • prevention of personal data processing incompatible with the purposes of personal data collection;
  • preventing the merging of databases containing personal data processed for incompatible purposes;
  • processing only those personal data that meet the purposes of their processing;
  • compliance of the content and scope of processed personal data with the stated processing purposes;
  • preventing the processing of personal data that are redundant in relation to the stated purposes of their processing;
  • ensuring accuracy, sufficiency and relevance of personal data in relation to the purposes of personal data processing;
  • destruction or depersonalization of personal data upon achievement of the purposes of their processing or in case of loss of necessity in achievement of these purposes, in case of impossibility of elimination of personal data violations by the Operator, unless otherwise provided by the federal law.

2.2. Conditions of personal data processing

The Operator processes personal data under at least one of the following conditions:

  • processing of personal data is carried out with the consent of the personal data subject to the processing of his/her personal data;
  • the processing of personal data is necessary to achieve the purposes provided for by the international treaty of the Russian Federation or by law, to implement and fulfill the functions, powers and duties assigned to the operator by the legislation of the Russian Federation;
  • processing of personal data is necessary for the administration of justice, execution of a judicial act, an act of another authority or an official subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings;
  • processing of personal data is necessary for the execution of an agreement to which the personal data subject is a party, beneficiary or guarantor, as well as for the conclusion of an agreement at the initiative of the personal data subject or an agreement under which the personal data subject will be a beneficiary or guarantor;
  • the processing of personal data is necessary for the exercise of rights and legitimate interests of the operator or third parties or for the achievement of socially important goals, provided that the rights and freedoms of the personal data subject are not violated;
  • personal data is processed if it is accessible to an unlimited number of persons by the personal data subject or at his/her request (hereinafter referred to as publicly available personal data);
  • processing of personal data subject to publication or mandatory disclosure in accordance with federal law.

2.3. Confidentiality of personal data

The operator and other persons who have access to personal data are obliged not to disclose to third parties and not to disseminate personal data without the consent of the subject of personal data, unless otherwise provided for by federal law.


2.4. Publicly available sources of personal data

For information support purposes, the Operator may create publicly available sources of personal data of subjects, including directories and address books. Publicly available sources of personal data may include the subject's surname, name, patronymic, date and place of birth, position, contact telephone numbers, e-mail address and other personal data provided by the subject of personal data with the written consent of the subject. Information about the subject shall be excluded from publicly available sources of personal data at any time at the request of the subject or by decision of the court or other authorized state bodies.


2.5. Special categories of personal data

Processing by the Operator of special categories of personal data concerning race, nationality, political opinions, religious or philosophical beliefs, state of health, intimate life is allowed if:

  • the personal data subject has consented in writing to the processing of his/her personal data;
  • personal data is made publicly available by the subject of personal data;
  • processing of personal data is carried out in accordance with the legislation on state social assistance, labor legislation, legislation of the Russian Federation on state pension provision, on labor pensions;
  • processing of personal data is necessary to protect the life, health or other vital interests of the personal data subject or the life, health or other vital interests of other persons and it is impossible to obtain the consent of the personal data subject;
  • processing of personal data is carried out for medical and preventive purposes, in order to establish a medical diagnosis, to provide medical and medical-social services, provided that the processing of personal data is carried out by a person professionally engaged in medical activity and obliged to keep medical secrecy in accordance with the legislation of the Russian Federation;
  • the processing of personal data is necessary for the establishment or exercise of the rights of the personal data subject or third parties, as well as in connection with the execution of justice;
  • processing of personal data is carried out in accordance with the legislation on compulsory types of insurance, insurance legislation.

Processing of special categories of personal data shall be immediately stopped if the reasons due to which their processing was carried out are eliminated, unless otherwise established by federal law.


Processing of personal data on criminal record may be carried out by the Operator only in cases and in the manner determined in accordance with federal laws.


2.6. Biometric personal data

Information that characterizes physiological and biological features of a person on the basis of which his/her identity can be established - biometric personal data - may be processed by the Operator only with the written consent of the subject.


2.7. Assignment of personal data processing to another pers

The Operator has the right to entrust personal data processing to another person with the consent of the personal data subject, unless otherwise provided for by federal law, on the basis of a contract concluded with this person. The person processing personal data on behalf of the Operator is obliged to comply with the principles and rules of personal data processing stipulated by the Law.


2.8. Cross-border transfer of personal data

The operator is obliged to make sure that the foreign state, to the territory of which it is supposed to transfer personal data, provides adequate protection of the rights of personal data subjects, before the beginning of such transfer.


At the same time, the operator performing transborder transfer of personal data shall be guided by the legislation of the foreign state, to the territory of which the transfer of personal data is carried out, the legislation of the Russian Federation in the field of protection of the rights of personal data subjects, as well as international normative acts, including the Convention for the Protection of Individuals with regard to Automatic Processing of Personal Data of January 28, 1981 ETS No. 108, taking into account the list of countries that have signed and ratified this Convention.


Transborder transfer of personal data in the territories of foreign states that do not ensure adequate protection of the rights of personal data subjects may be carried out in cases:

  • the personal data subject's written consent to the trans-border transfer of his/her personal data;
  • execution of a contract to which the personal data subject is a party.

RIGHTS OF THE PERSONAL DATA SUBJECT


3.1. Consent of the personal data subject to the processing of his/her personal data

The subject of personal data decides to provide his/her personal data and consents to their processing freely, of his/her own free will and in his/her own interest. Consent to the processing of personal data may be given by the subject of personal data or his/her representative in any form that allows to confirm the fact of its receipt, unless otherwise established by federal law.


The obligation to provide proof of receipt of the personal data subject's consent to the processing of his/her personal data or proof of the existence of the grounds specified in the Law is imposed on the Operator.


3.2. Rights of the personal data subject

The subject of personal data has the right to receive information from the Operator regarding the processing of his/her personal data, unless such right is restricted in accordance with federal laws. The subject of personal data has the right to demand from the Operator to clarify his/her personal data, block or destroy it if the personal data is incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing, as well as to take measures provided for by law to protect his/her rights.


Processing of personal data for the purpose of promoting goods, works, services on the market by means of direct contacts with potential consumers, as well as for political agitation purposes is allowed only with the prior consent of the personal data subject. The said processing of personal data is recognized as being carried out without the prior consent of the subject of personal data, unless the Company proves that such consent was obtained.


The operator is obliged to immediately stop processing of personal data for the above purposes at the request of the personal data subject.


It is prohibited to make decisions on the basis of exclusively automated processing of personal data that give rise to legal consequences in relation to the subject of personal data or otherwise affect his/her rights and legitimate interests, except in cases provided for by federal laws or with the consent in writing of the subject of personal data.


If a personal data subject believes that the Operator processes his/her personal data in violation of the requirements of the Law or otherwise violates his/her rights and freedoms, the personal data subject has the right to appeal the actions or inaction of the Operator to the Authorized Body for the Protection of the Rights of Personal Data Subjects or in court.


The subject of personal data has the right to protect his/her rights and legitimate interests, including compensation for losses and (or) compensation for moral damage in court.


PERSONAL DATA PROTECTION


Other rights and obligations of the Operator as an operator of personal data shall be determined by the legislation of the Russian Federation in the field of personal data.


The Operator's officials guilty of violating the norms governing the processing and protection of personal data shall bear material, disciplinary, administrative, civil or criminal liability in accordance with the procedure established by federal laws.


To prevent unauthorized access to personal data, the Operator applies the following organizational and technical measures:

  • appointment of officials responsible for the organization of processing and protection of personal data;
  • limitation of persons having access to personal data;
  • familiarization of subjects with the requirements of federal legislation and the Operator's regulatory documents on processing and protection of personal data;
  • organization of accounting, storage and circulation of data carriers;
  • determination of threats to personal data security during their processing, formation of threat models on their basis;
  • development of the personal data protection system based on the threat model;
  • verification of readiness and efficiency of information protection means utilization;
  • delimitation of users' access to information resources and hardware and software means of information processing;
  • registration and recording of actions of users of personal data information systems;
  • use of antivirus and recovery means of the personal data protection system;
  • application of firewalling, intrusion detection, security analysis and cryptographic protection tools where necessary;
  • organization of access control to the Operator's territory, security of premises with technical means of personal data processing.

CONCLUDING PROVISIONS


Other rights and obligations of the Operator as a personal data operator are determined by the legislation of the Russian Federation in the field of personal data.


The Operator's officials guilty of violating the norms regulating the processing and protection of personal data shall bear material, disciplinary, administrative, civil or criminal liability in accordance with the procedure established by federal laws.

Made on
Tilda