PLANETHUB MULTICORP PVT LTD. – GDPR & EU DATA PROTECTION POLICY
24x7ServerSupport is a Product of PLANETHUB MULTICORP PVT LTD.
24x7ServerSupport prioritizes customer trust. We know that customer data is important to our customers’ values and operations. That is why we keep it private and safe.
24x7ServerSupport helps customers maintain control of their privacy and data security in a myriad of ways:
Data Security: We provide our customers with compliance with high-security standards, such as encryption of data in motion over public networks, auditing standards (ISO 27001:2013), and a Support team that is available 24/7.
Disclosure of Customer Service Data: 24x7ServerSupport does not disclose any of its customers’ data or any contact details to any third parties unless required to respond to lawful requests from public authorities.
Access Management: 24x7ServerSupport provides an advanced set of access and encryption features to help customers effectively protect their information. We do not access or use customer content for any purpose other than providing, maintaining, and improving the 24x7ServerSupport services and as otherwise required by law.
What is service data?
Service Data is any information, including personal data, which is stored in or transmitted via the 24x7ServerSupport services, by, or on behalf of, our customers and their end-users.
Who owns and controls Service Data?
From a privacy perspective, the customer is the controller of Service Data, and 24x7ServerSupport is a processor. This means that throughout the time that a customer subscribes to services with 24x7ServerSupport, the customer retains ownership of and control over Service Data in its account.
How does 24x7ServerSupport use Service Data?
We use Service Data to operate and improve our services, help customers access and use the services, respond to customer inquiries, and send communication-related to the services.
What steps does 24x7ServerSupport take to secure Service Data?
24x7ServerSupport prioritizes data security and combines enterprise-class security features with comprehensive audits of our applications, systems, and networks to ensure customer and business data is always protected.
For example, 24x7ServerSupport servers are hosted at Tier IV or III+, SSAE-16, PCI DSS, or ISO 27001 compliant facilities. and our Support team is on call 24/7 to respond to security alerts and events.
How does 24x7ServerSupport Respond to Information Requests?
24x7ServerSupport recognizes that privacy and data security issues are top priorities for customers.
24x7ServerSupport does not disclose Service Data except as necessary to provide its services to its customers and comply with the law as detailed in our Privacy Policy.
24x7ServerSupport has achieved internationally-recognized ISO 27001:2013 certifications and accreditations demonstrating compliance with third-party assurance frameworks.
How does 24x7ServerSupport respond to legal requests for Service Data?
In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We may disclose personal data to respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims. We may also share such information with relevant law enforcement agencies or public authorities if we believe same to be necessary in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our Terms of Services, or as otherwise required by law.
EU DIRECTIVE
The EU Data Protection Directive (also known as “Directive 95/46/EC“) addresses the processing of personal data and the free movement of such data. Broadly, this Directive sets out several data protection principles and requirements that must be adhered to when personal data is processed.
Directive 95/46/EC established the Article 29 Working Party (“WP29”), which is comprised of representatives from the data protection authorities of all the EU Member States as well as from the European Commission. WP29 works to harmonize the application of data protection rules throughout the EU and also advises the EU Commission on the adequacy of data protection standards in non-EU countries.
How does the EU Directive apply to customers?
24x7ServerSupport customers who collect and store personal data are considered data controllers under Directive 95/46/EC. Data controllers bear the primary responsibility for ensuring that their processing of personal data is compliant with relevant EU data protection law, including Directive 95/46/EC and the GDPR as of May 25, 2018.
What is a Data Processing Agreement (“DPA”)?
24x7ServerSupport offers customers a robust Data Processing Agreement (“DPA”), governing the relationship between the customer (acting as a data controller) and 24x7ServerSupport (acting as a data processor). The DPA facilitates 24x7ServerSupport’s customers’ compliance with their obligations under EU data protection law. Our DPA contains strong privacy commitments and has been updated to confirm our compliance with the GDPR as and from May 25, 2018. Our DPA contains data transfer frameworks to ensure that our customers can lawfully transfer personal data to 24x7ServerSupport outside of the European Union by relying on mechanisms of Standard Contractual Clauses.
What are the “Model Clauses”?
The European Commission has approved a set of standard provisions called the Standard Contractual Clauses (“Model Clauses”) which provide a data controller a compliant mechanism to transfer personal data to a data processor outside the European Economic Area (“EEA”). The Model Clauses are appended to the 24x7ServerSupport DPA to help provide adequate protection for data transfer outside of the EEA or Switzerland.
GDPR
Since our inception, the 24x7ServerSupport approach has been anchored with a strong commitment to privacy, security, compliance, and transparency. This approach includes supporting our customers’ compliance with EU data protection requirements, including those set out in the General Data Protection Regulation (“GDPR”), which becomes enforceable on May 25, 2018.
If a company collects, transmits, hosts or analyzes personal data of EU citizens, GDPR requires the company to use third-party data processors who guarantee their ability to implement the technical and organizational requirements of the GDPR. To further earn our customers’ trust, our DPA has been updated to provide our customers with contractual commitments regarding our compliance with applicable EU data protection law and to implement additional contractual provisions required by the GDPR. Our contractual commitments guarantee that customers can:
Respond to requests from data subjects to correct, amend or delete personal data.
Be made aware of and report personal data breaches to relevant supervisory authorities and data subjects in accordance with GDPR timeframes.
Demonstrate their compliance with the GDPR as pertaining to 24x7ServerSupport Services.
PLANETHUB MULTICORP PVT LTD GDPR PRODUCT READINESS
The General Data Protection Regulation (GDPR), which goes into effect on May 25, 2018, provides data subjects with an array of privacy rights, which provide individuals with greater transparency into and control over the use of their personal information.
The features and functionalities that are currently available. As we approach May 25, 2018 (GDPR Effective Date), 24x7ServerSupport will be updating and adding features and functionalities further to support our customers with their GDPR compliance programs.
What is the GDPR?
The General Data Protection Regulation (“GDPR”) is a new European privacy regulation that will replace the current EU Data Protection Directive (“Directive 95/46/EC”). The GDPR aims to strengthen the security and protection of personal data in the EU and harmonize EU data protection law.
To whom does the GDPR apply?
The GDPR applies to all organizations operating in the EU and processing “personal identifiable data” of EU residents. Personal data is any information relating to an identified or identifiable natural person.
What implications does GDPR have for organizations processing the personal data of EU citizens?
One of the key aspects of the GDPR is that it creates consistency across EU member states on how personal data can be processed, used, and exchanged securely. Organizations will need to demonstrate the security of the data they are processing and their compliance with GDPR on a continual basis, by implementing and regularly reviewing robust technical and organizational measures, as well as compliance policies.
How has 24x7ServerSupport been preparing for the GDPR?
24x7ServerSupport will be compliant with the GDPR when it becomes enforceable in May 2018. Our privacy team is working with customers around the world to answer their questions and to help them prepare for using 24x7ServerSupport Services after the GDPR becomes effective. Additionally, our privacy team is reviewing 24x7ServerSupport current product features and practices to ensure we support our customers with their GDPR compliance requirements.
How can 24x7ServerSupport customers prepare for GDPR enforcement?
24x7ServerSupport encourages customers to begin preparing for the GDPR by reviewing their privacy and data security processes and policies to ensure compliance by May 2018. Data controllers bear the primary responsibility for ensuring that their processing of personal data is compliant with EU data protection law. Below are some key points to consider for GDPR compliance:
Geographical Application:The GDPR may apply to organizations that are established in the EU as well as certain organizations established outside the EU but which are processing the personal data of EU citizens, depending on their activities.
Rights of End-Users:Organizations should be cognizant of End-Users whose personal data they may be processing. The GDPR establishes enhanced rights for End-Users, and organizations should be able to accommodate those rights.
Data Breach Notifications:Organizations that are controllers of personal data should have clear processes in place in order to comply with the GDPR requirement to report data breaches in accordance with the time frames set out within the GDPR. 24x7ServerSupport will notify affected customers without undue delay if we become aware of a data breach of our services.
Appointment of Data Protection Officer (“DPO”):Customers may need to appoint DPOs to manage issues relating to the processing of personal data.
Data Protection Impact Assessment (“DPIA”):DPIAs usually describe organizations data processes and protective measures, particularly those that may be risky. For data processing activities, customers need to conduct and file with authorities a DPIA.
Which 24x7ServerSupport services and features can support customer’s compliance with the GDPR?
Customers can use 24x7ServerSupport third-party ISO certification to help conduct their risk assessments and determine whether appropriate technical and organizational measures are in place.
Below are examples of specific 24x7ServerSupport product features that customers can utilize to assist with the GDPR compliance program. Through our Advanced Security Deployed Associated Service, customers can choose to obtain enhanced features, including enhanced disaster recovery and encryption, as well as the ability to configure for the Health Insurance Portability and Accountability Act (“HIPAA”).
Currently, available features for specific 24x7ServerSupport products can be found in the questions/answers below.
Auditing Standards:
ISO 27001:2013 certified
Scanning:
Static scanning of code repositories
Encryption:
Encryption of data in motion over public networks
Encryption of certain data at rest with AES256 (Optional Add-on feature)
Does 24x7ServerSupport provide any product-specific Features/Functionality in its products to assist us with our GDPR compliance program?
24x7ServerSupport provides customers the option to delete Service Data that may contain personal data, such as profiles, payment methods in active 24x7ServerSupport Support accounts.
End-User themselves can modify their profile from end user portal.
Both Administrators and Agents can delete End-User profiles from the staff portal as long as they have permission set under their roles by the Administrator.
Following this deletion action, the End-User profile is removed from the User Interface, and the End-User identity is deleted from the system, along with the tickets and other data is also deleted. e.g. solution comments, forum topics/comments, invoice, and profile information.
PLANETHUB MULTICORP PVT LTD CERTIFICATIONS:
