This document covers the personal data we handle in our role as data processor, but also how we ensure that data subjects and other, third party, data processors are interacted with in accordance with the General Data Protection Regulation and professional standards.
In the following, the term “Personal Data” is defined as data which identify, or may identify, an individual.
Bisbo Advisory acts first and foremost as data processor processing client data, which are most often limited to name, email address and birth details (date, time of day and geographical place of the individual’s birth). It can, however, also in some cases consist of descriptions of personal experiences that could, in very specific circumstances, assist in revealing a client’s identity.
The data are used in connection with delivering the services requested of Bisbo Advisory, i.e. personal analyses and/or group analyses. By requesting our services, the client agrees to let Bisbo Advisory collect, store and process the client data for Bisbo Advisory to deliver the requested service. We are always ready to provide information on which personal data are kept for any individual provided such requests are made by an individual authorised to receive this information.
The personal data for clients are kept for as long as the contractual relationship exists or until such time the client requests to have his or her personal data amended or deleted. When the contractual relationship ends, the data are deleted or anonymised as soon as practically possible unless Bisbo Advisory is legally required to maintain data by government authorities. Bisbo Advisory reserves the right to use anonymised data for the purpose of lectures, workshops and general teaching material. Non-anonymised data will only be used based on explicit permission from the client.
Upon request from a client, Bisbo Advisory will always inform which and what kind of data regarding the client is in our possession.
Bisbo Advisory uses data sub processors only to the extent absolutely necessary like for example IT support and webpage design and maintenance and all such sub processors must comply with the same level of security and confidentiality as Bisbo Advisory does based on a written “Sub data Processing Agreement”. We are always ready to provide a full list of sub processors when requested.
All personal data in Bisbo Advisory’s possession are stored on password protected computers situated at an office with restricted access to which only Bisbo Advisory staff have access.
If Bisbo Advisory discovers or suspects that any sensitive, protected or confidential data are copied, transmitted, viewed, stolen or used by an individual or an organisation unauthorized to do so, Bisbo Advisory will inform all affected parties as soon as possible. This includes, but is not limited to, hackers, unauthorised loss, processing, alteration or destruction of personal data, and the data controllers, processors and/or sub processors’ failure to comply with applicable law(s), respective agreements or privacy policies. In these cases, Bisbo Advisory will, to the extent possible, provide the affected parties with 1) a detailed description of the severity of the breach, 2) contact information on the party/parties responsible for the data protection in the affected area(s) as well as the party/parties affected by the breach, 3) potential consequences of the breach and 4) a description of the measures the responsible party/parties must take, and/or measures already taken, in order to limit the adverse effects of the breach.
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In the event you have requested to receive our newsletter, Bisbo Advisory shall store your name and email address via MailChimp for that purpose only. It is always possible to unsubscribe to our newsletter in which case your data shall be immediately deleted.
Henrik Bisbo, Partner – 1 August 2019