Data Deletion Policy
This document sets out TRATE policy for responding to requests for deletion of data under the GDPR (General Data Protection Regulation), which comes into force in May 25th of 2018. This document explains the rights of the data subject in relation to data deletion and the responsibilities of TRATE in responding with such a request.
An individual has the right to erasure, also known as ‘the right to be forgotten’. The principle underpinning this right is to enable an individual to request the deletion or removal of personal data where there is no compelling reason for its continued processing.
When does the right to erasure apply?
As stipulated in the GDPR, individuals have a right to have personal data erased and to prevent processing in specific circumstances:
- Where the personal data is no longer necessary in relation to the purpose for which it was originally collected/processed;
- When the individual withdraws consent;
- When the individual objects to the processing and there is no other legal ground for the relevant processing activity;
- When the personal data was unlawfully processed;
- Where the personal data has to be erased in order to comply with a legal obligation.
What information does TRATE retain?
The TRATE Internet page and offered services (such as courses) stores data about individuals. TRATE stores the name or user name, e-mail address, IP, organisation/department (if provided) and interest in TRATE’s services or product for each individual in order to create an offer, which is stored on our secure servers in the Europe for a period of 4 years after the last interaction with TRATE Company.
If consent is provided, personal data (including the above, plus address, telephone number, budget, interest, send files, telephone calls, messages and notes) may be stored in our CRM system for the purposes of contacting you regarding TRATE news, products and promotions.
How can data be deleted?
A system administrator (individual user acting on behalf of our or our partners organization) can delete data from system whenever they wish. This data is deleted from the system immediately and cannot be recovered by any users or TRATE employees after this point. Data which has been deleted or otherwise destroyed can not be recovered at any time. Sufficient warning is given to the account administrator before they permanently delete anything. Data which is saved under the law, for example – financial reports, audit information can not be deleted.
Deleted data may still remain in the systems back-up files for a while, which will be deleted periodically.
Information may be deleted from our CRM system upon request to firstname.lastname@example.org. We undertake to perform the deletion within one month (30 calendar days) if Your requested information can be deleted and will send you a confirmation once the information has been deleted.
Wherever possible, we will aim to complete the request in advance of the deadline.