mirror of
https://github.com/aeris/gdpr
synced 2024-06-17 13:15:09 +02:00
163 lines
7.2 KiB
Markdown
163 lines
7.2 KiB
Markdown
|
Dear Sir/Madam:
|
|||
|
|
|||
|
I am writing to you in your capacity as data protection officer for your
|
|||
|
company. In light of recent spam received on this email address,
|
|||
|
I am making this request for access to personal data
|
|||
|
pursuant to Article 15 of the General Data Protection Regulation.
|
|||
|
I am concerned that your company’s information practices may be putting my
|
|||
|
personal information at undue risk of exposure or in fact has breached its
|
|||
|
obligation to safeguard my personal information.
|
|||
|
|
|||
|
I proof my identity and this email address property by signing this email with
|
|||
|
my GPG key 0xefb74277ece4e222.
|
|||
|
If you require further information, please contact me at my address above.
|
|||
|
|
|||
|
I would like you to be aware at the outset, that I anticipate reply to my
|
|||
|
request within one month as required under Article 12, failing which I will be
|
|||
|
forwarding my inquiry with a letter of complaint to the CNIL (French RGPD
|
|||
|
regulator).
|
|||
|
|
|||
|
Please advise as to the following:
|
|||
|
|
|||
|
1. Please confirm to me whether or not my personal data is being processed.
|
|||
|
If it is, please provide me with the categories of personal data you have
|
|||
|
about me in your files and databases.
|
|||
|
|
|||
|
a. In particular, please tell me what you know about me in your
|
|||
|
information systems, whether or not contained in databases, and including e-
|
|||
|
mail, documents on your networks, or voice or other media that you may store.
|
|||
|
|
|||
|
b. Additionally, please advise me in which countries my personal data is
|
|||
|
stored, or accessible from. In case you make use of cloud services to store or
|
|||
|
process my data, please include the countries in which the servers are located
|
|||
|
where my data are or were (in the past 12 months) stored.
|
|||
|
|
|||
|
c. Please provide me with a copy of, or access to, my personal data that
|
|||
|
you have or are processing.
|
|||
|
|
|||
|
2. Please provide me with a detailed accounting of the specific uses that
|
|||
|
you have made, are making, or will be making of my personal data.
|
|||
|
|
|||
|
3. Please provide a list of all third parties with whom you have (or may
|
|||
|
have) shared my personal data.
|
|||
|
|
|||
|
a. If you cannot identify with certainty the specific third parties to
|
|||
|
whom you have disclosed my personal data, please provide a list of third
|
|||
|
parties to whom you may have disclosed my personal data.
|
|||
|
|
|||
|
b. Please also identify which jurisdictions that you have identified in
|
|||
|
1(b) above that these third parties with whom you have or may have shared my
|
|||
|
personal data, from which these third parties have stored or can access my
|
|||
|
personal data. Please also provide insight in the legal grounds for
|
|||
|
transferring my personal data to these jurisdictions. Where you have done so,
|
|||
|
or are doing so, on the basis of appropriate safeguards, please provide a
|
|||
|
copy.
|
|||
|
|
|||
|
c. Additionally, I would like to know what safeguards have been put in
|
|||
|
place in relation to these third parties that you have identified in relation
|
|||
|
to the transfer of my personal data.
|
|||
|
|
|||
|
4. Please advise how long you store my personal data, and if retention is
|
|||
|
based upon the category of personal data, please identify how long each
|
|||
|
category is retained.
|
|||
|
|
|||
|
5. If you are additionally collecting personal data about me from any source
|
|||
|
other than me, please provide me with all information about their source, as
|
|||
|
referred to in Article 14 of the GDPR.
|
|||
|
|
|||
|
6. If you are making automated decisions about me, including profiling,
|
|||
|
whether or not on the basis of Article 22 of the GDPR, please provide me with
|
|||
|
information concerning the basis for the logic in making such automated
|
|||
|
decisions, and the significance and consequences of such processing.
|
|||
|
|
|||
|
7. I would like to know whether or not my personal data has been disclosed
|
|||
|
inadvertently by your company in the past, or as a result of a security or
|
|||
|
privacy breach.
|
|||
|
|
|||
|
a. If so, please advise as to the following details of each and any such
|
|||
|
breach:
|
|||
|
|
|||
|
i. a general description of what occurred;
|
|||
|
|
|||
|
ii. the date and time of the breach (or the best
|
|||
|
possible estimate);
|
|||
|
|
|||
|
iii. the date and time the breach was discovered;
|
|||
|
|
|||
|
iv. the source of the breach (either your own
|
|||
|
organization, or a third party to whom you have transferred my personal data);
|
|||
|
|
|||
|
v. details of my personal data that was disclosed;
|
|||
|
|
|||
|
vi. your company’s assessment of the risk of harm to
|
|||
|
myself, as a result of the breach;
|
|||
|
|
|||
|
vii. a description of the measures taken or that will
|
|||
|
be taken to prevent further unauthorized access to my personal data;
|
|||
|
|
|||
|
viii. contact information so that I can obtain more
|
|||
|
information and assistance in relation to such a breach, and
|
|||
|
|
|||
|
ix. information and advice on what I can do to protect
|
|||
|
myself against any harms, including identity theft and fraud.
|
|||
|
|
|||
|
b. If you are not able to state with any certainty whether such an
|
|||
|
exposure has taken place, through the use of appropriate technologies, please
|
|||
|
advise what mitigating steps you have taken, such as
|
|||
|
|
|||
|
i. Encryption of my personal data;
|
|||
|
|
|||
|
ii. Data minimization strategies; or,
|
|||
|
|
|||
|
iii. Anonymization or pseudonymization;
|
|||
|
|
|||
|
iv. Any other means
|
|||
|
|
|||
|
8. I would like to know your information policies and standards that you
|
|||
|
follow in relation to the safeguarding of my personal data, such as whether
|
|||
|
you adhere to ISO27001 for information security, and more particularly, your
|
|||
|
practices in relation to the following:
|
|||
|
|
|||
|
a. Please inform me whether you have backed up my personal data to
|
|||
|
tape,
|
|||
|
disk or other media, and where it is stored and how it is secured, including
|
|||
|
what steps you have taken to protect my personal data from loss or theft, and
|
|||
|
whether this includes encryption.
|
|||
|
|
|||
|
b. Please also advise whether you have in place any technology which
|
|||
|
allows you with reasonable certainty to know whether or not my personal data
|
|||
|
has been disclosed, including but not limited to the following:
|
|||
|
|
|||
|
i. Intrusion detection systems;
|
|||
|
|
|||
|
ii. Firewall technologies;
|
|||
|
|
|||
|
iii. Access and identity management technologies;
|
|||
|
|
|||
|
iv. Database audit and/or security tools; or,
|
|||
|
|
|||
|
v. Behavioral analysis tools, log analysis tools, or
|
|||
|
audit tools;
|
|||
|
|
|||
|
9. In regards to employees and contractors, please advise as to the
|
|||
|
following:
|
|||
|
|
|||
|
a. What technologies or business procedures do you have to ensure
|
|||
|
that
|
|||
|
individuals within your organization will be monitored to ensure that they do
|
|||
|
not deliberately or inadvertently disclose personal data outside your company,
|
|||
|
through e-mail, web-mail or instant messaging, or otherwise.
|
|||
|
|
|||
|
b. Have you had had any circumstances in which employees or
|
|||
|
contractors
|
|||
|
have been dismissed, and/or been charged under criminal laws for accessing my
|
|||
|
personal data inappropriately, or if you are unable to determine this, of any
|
|||
|
customers, in the past twelve months.
|
|||
|
|
|||
|
c. Please advise as to what training and awareness measures you have
|
|||
|
taken in order to ensure that employees and contractors are accessing and
|
|||
|
processing my personal data in conformity with the General Data Protection
|
|||
|
Regulation.
|
|||
|
|
|||
|
Regards,
|