This document describes relevant GDPR processes at Compassion Consulting. The document is updated when needed, and as a minimum yearly, in addition the assessment of consequences for the management of personal data is updated yearly.
Process for deletion of personal data
The criteria for deletion of personal data in Compassion Consulting is as follows: Personal data is deleted two years after the end of the last programme or coaching session with the person.
For data that is secured in Office 365, a manual deletion of the personal data that applies to the deletion criteria will happen every 3 months.
For paper note books there is a yearly proces, and if any data in the note book applies to the criteria for deletion it will be either maculated or burned so that any personal data is securely deleted.
Legality of data management
Compassion Consulting is the data manager on behalf of several companies and hence has to secure, that the data management happening is in accordance with the rules of GDPR.
Compassion Consulting only does data management when there is a written agreement with the data owner, and in accordance with the instructions for data management given by the data owner.
Compassion Consulting will only do data management following the primary activities. I. e. Compassion Consulting offers coaching and other personal and team development. This means that Compassion Consulting keeps and exchanges the following personal data in an electronic format: first name, last navn, telephone nummer and email address with data owners and sub-contractors.
The data are being used to identify persons and to communicate with them during the programmes and other activities the person participates in.
Compassion Consulting only does data management that is necessary for the delivery of an agreed service. This means that Compassion Consulting does not do data management on for example:
- data about persons that are not part of an agreed service
- data that aren't directly necessary for the primary activities
If there is a need for doing a preference or personality profile during a programme or agreed service, Compassion Consulting will provide name and email address to the relevant sub-contractor.
Compassion Consulting uses 3 sub-contractors:
- Microsoft, supplies Office 365 where all personal data is primarily kept and exchanged
- HBDI.dk supplies preference profiles and reports on preferences based on the profile
- A&D Resources supplies personality tests and reports about personality based on the test
Data management agreements have been made with sub-contractors.
If Compassion Consulting changes sub-contractor, relevant data owners will be informed.
By signing agreements with Compassion Consulting the data owner accepts that Compassion Consulting follows the GDPR processes described in this document, and that the listed sub-contractors are used.