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The General Data Protection Regulation (GDPR) will, once it takes effect on May 25th 2018, replace the European Data Protection Directive and existing relevant national legislation. GDPR aims to strengthen the Individual’s rights, secure their personal data and protect their privacy. The introduction of GDPR will provide Data Subjects improved rights for transparency, and easier access to have data corrected, transferred and/or completely deleted.
Basefarm is a Data Controller for data collected and processed by internal functions and processes. This include shareholder and employee data, and data collected about prospective and existing customers. It also includes data about vendor’s personnel, partner’s personnel, contractors and other persons who have been, or are, in contact with Basefarm through digital channels. Taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk, Basefarm applies appropriate and reasonable organizational and technical security measures to protect these datasets.
Basefarm is a Data Processor when managing services that store, transfer or process personal data on behalf of our customers, where the customer is a Data Controller. Some customers are themselves Data Processors, in which case Basefarm has the role as Sub-Processor. The GDPR defines “Personal Data” as any information relating to an identified or identifiable natural person, meaning that almost any IT system must be considered to carry personal data. Basefarm will only perform processing activities on the Personal Data based on documented instructions from the relevant customer. Basefarm will not engage sub-processors without the prior written approval of the relevant customer.
Basefarm’s Information Security Management System (ISMS) is ISO27001 certified. The scope is all-inclusive; thus, it covers all operation activities, all Data Centers and all offices in Norway, Sweden and The Netherlands. Basefarm also offers subscription-based SOC2 and ISAE3402 attestation services.
Our Data Center facilities are all designed, built and operated according to TIER III principles. Physical security controls are layered, based on balanced security principles designed to have adequate response in place before a physical intrusion is successful. Access is restricted to selected personnel only. The physical security of our Data Centers is reviewed annually as a part of the ISO 27001 audits.
Basefarm performs screening of employees relevant to their tasks and responsibilities, and within limitations in local legislation. All employees are required to sign non-disclosure agreements prior to being granted access to IT systems. Further, all employees are required to read and adhere to relevant parts of Basefarm’s security policies, and are subject to security awareness training, at least annually.
As a Data Processor or a Sub-Processor, Basefarm provides services with a default security level that for many customers and processing activities will be sufficient to meet the requirements of GDPR. However, the Data Controllers must assess the risk involved in the processing, and determine the need for additional technical or organizational security measures. Basefarm offers a range of security services that will increase Data Protection, or ensure faster detection and improved response capabilities in case of security incidents or Data Breaches. Ultimately, it is the customer that will decide on what (if any) additional security measure that are needed.
Basefarm operations are governed by well-defined and mature processes, based on ITIL and ISO9001.
Basefarm has appointed a Data Protection Officer (DPO). The DPO monitors Basefarm’s commitment to, and execution of, activities needed to comply with GDPR. The DPO also works externally with suppliers, partners and customers as an advisor, to ensure that the parties provide data subjects with the general data protection and data privacy that is required, and that Service Agreements are kept up-to-date to define the roles and responsibilities of each Party. The DPO is also the primary liaison between Basefarm and national Data Protection Agencies. The DPO can be reached at DPO@basefarm.com.
Basefarm uses Data Processing Agreements to document the specific Personal Data processing obligations and responsibilities we undertake on behalf of our customers. The DPAs will be added to the Service Agreements, and shall substitute any existing agreement governing Personal Data processing. Similarly, Basefarm signs Data Processing Agreements with sub-contractors and partners if the service they provide includes access to, or processing activities on, Personal Data.
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Cookies are also used to collect information on how the website is used. In addition, with our cooperation partners we collect anonymous information of which browsers that visit the website to show relevant advertising (interest based advertising).
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1.4 More detailed information
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2. Data controller Basefarm AS, reg. no. 982 211 743, Nydalen Allé 37a, 0484 Oslo, Norway, is the data controller in relation to personal data being processed on the Norwegian and English versions of the website. Basefarm AB, reg. no. 556638-0639, Sveavägen 159, 113 46 Stockholm, Sweden, is the data controller in relation to personal data being processed on the Swedish version of the website. Basefarm BV reg. no. [•], Beechavenue 106, 1119 PP Schiphol-Rijk, Netherlands, is the data controller in relation to personal data being processed on the Dutch version of the website. The aforementioned Basefarm entities are collectively referred to as “Basefarm” in the following. You will find Basefarm’s contact information under section 10.
4. What data may Basefarm collect? The personal data Basefarm may collect includes information about your name and contact details such as address, telephone number and e-mail address, company and any other information you provide. If you apply for a job at Basefarm, Basefarm will process your CV as well as any other information you attach with your application.
5. How does Basefarm process personal data? The personal data collected by Basefarm is used to manage customer relations, assess potential employees and assist customers and website visitors with any requests or inquiries made on the website. The information may also be used for monitoring and development of Basefarm’s business and website, for example by analyzing statistics of website visitors, and to protect Basefarm’s rights. If you apply for a job, Basefarm only uses your personal data for the purposes for which you provided the information. However, Basefarm may save interesting applications even after the recruitment period is over. Such applications may also be transferred to other entities within the Basefarm group.
6. To whom may Basefarm disclose the information? Basefarm will not sell, lease or otherwise transfer any personal data collected to a third party. Basefarm may however transfer the personal data to other companies within the Basefarm group or to business partners if it is necessary to fulfil its obligations towards you. Personal data may be disclosed if it is necessary to: a) Comply with applicable law, regulation or similar or to comply with a legal process, request or order from an executive authority; b) Defend Basefarm’s legal interests; or to c) Detect, prevent, or otherwise avoid fraud, security breaches or technical issues.
7. Links to external websites Basefarm’s website may contain links to third-party websites. Basefarm is not responsible for the processing of your personal data on such websites.
8. Amendments If this policy is amended, Basefarm will publish the amended policy at www.basefarm.com with information about when the amendments will enter into force. If Basefarm carry out any significant changes to the policy, Basefarm may choose to inform by e-mail or by publishing a message on the website.
9. The right to information and recifications You have the right to require information about what personal data Basefarm is processing about you and for what purposes. You are also entitled to have any incomplete or inaccurate data rectified, erased or blocked. Please see the contact information in section 10 should you have any questions about how Basefarm processes your personal data.
10. Basefarm’s contact information If you have any questions relating to Basefarm’s processing of personal data, or if you want to invoke your right to access data, please contact relevant Basefarm entity on the address set out below: Norway/Global: Basefarm AS PO Box 4488 Nydalen 0403 Oslo Sweden: Basefarm AB Sveavägen 159 113 46 Stockholm Netherlands: Basefarm BV Beechavenue 106 1119 PP Schiphol-Rijk
11. Security measures Basefarm has taken the organizational and technical security measures required to protect personal data against unauthorized access, modification and deletion.
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