CSS Commerce GDPR
1. On May 25th 2018 the General Data Protection Regulation (GDPR) came into effect.
2. GDPR is now the main legislation in Europe that determines how personal data can be collected, stored and used.
3. Compliance with the Principles of GDPR.
a. Data must be processed lawfully, fairly and in a transparent manner in relation to individuals.
GDPR Allows Six Lawful Bases for processing. Consent is one of the six, but LEGITIMATE INTEREST is more applicable to B2B sales.
Legitimate Interest is one of the six lawful bases for processing personal data under the GDPR (General Data Protection Regulation). You must have a lawful basis in order to process personal data in line with the ‘lawfulness, fairness and transparency’ principle.
To comply with GDPR, CSS Commerce carried out a LEGITIMATE INTERESTS ASSESSMENT which is documented below:
The processing is necessary in order to supply Global Database’s clients with data for business-to-business marketing purposes; a lawful business objective specifically identified by the Privacy and Electronic Communications Regulations 2003 (PECR). Recital 47 of the GDPR identifies direct marketing as a legitimate use of personal information.
The data subjects are senior business people with decision making and budgetary responsibilities and can reasonably expect to be contacted with marketing material relating to their professional roles.
The data collected is limited to names of senior managers and directors, their job titles, company name, nationality, and phone and business email. If a person leaves their role, their name and contact details are deleted from the database
If a data subject requests that their data is removed from the database, it is suppressed so that it cannot be accessed or added again at a later date.
In supplying accurate, regularly updated and targeted data, Global Database provides a valuable service to business-to-business marketers. In the absence of Global Database and similar high quality service providers, corporate marketers would have to rely on limited, inaccurate and out-of-date data for their marketing needs, which would have a detrimental effect on the success of their businesses and the wider economy.
b. Data must be collected for specified, 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 not be considered to be incompatible with the initial purposes.
Data is collected solely for the purpose of compiling a database of business contacts to be used by CSS Commerce ‘s clients for business-to-business marketing.
c. Data must be adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
The data collected is limited to names of senior managers and directors, their job titles, company name, nationality, telephone numbers and business email addresses.
d. Data must be accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay.
CSS Commerce shall make every effort and diligence to ensure that these data are accurate and up-to-date. In any case, the person is entitled to rectification.
e. Data must be 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; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals.
If a person leaves their role, their name and contact details are deleted from the database. However, the information may still be used for suppression purposes i.e. to ensure that it cannot be added to the database again.
f. Data must be processed in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.
Data is only provided to companies offering legitimate business services that are relevant to the professional role of the data subject. CSS Commerce operates a rigorous data security environment.
g. Individuals have the right to see, correct, restrict access to or remove their personal information.
For subject access requests, use the contact details shown above.