Data protection policy

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Send an e-mail to:

privacy@implement.dk

Introduction

We are under an obligation to protect the confidentiality, integrity and accessibility of our customers’, suppliers’, partners’ and employees’ data, including personal data. Protecting personal data is essential to us, and we are continuously working on ensuring compliance with applicable data protection legislation, including the General Data Protection Regulation (GDPR).

Data controller

When Implement processes personal data in connection with the provision of consultancy services, we consider ourselves a data processor, as we process personal data on behalf of our customers and in accordance with customer instructions. The customer and Implement enter into a data processing agreement containing instructions, terms and conditions for Implement’s processing of personal data.

This data protection policy contains information on Implement’s processing of personal data, when we are the data controller. More information on this may be found below.

Our processing activities

The data controller for Implement’s processing activities is the company within the Implement group of companies which determines the purposes and means of the processing of personal data.

The company details for all of the Implement group of companies may be found here.

You can read more on the categories of personal data that we process for which purposes and on which legal grounds in the table below:

Data controller

Purpose

Data subject(s)

Category of personal data Legal basis Source Retention period Disclosure to third parties
The company which has entered into a contract or an engagement letter with the client. Management of customer relations, including financial and contract administration. Clients and customers, including their employees. Non-sensitive personal data, i.e. name, position, contact details. Processing of personal data is necessary for the performance of contracts with the customer, cf. GDPR, Article 6(1)(b). Processing is also necessary in order for Implement to pursue its legitimate interests in being able to manage contracts, invoice and evaluate the customer relationship, manage and maintain IT systems, administer and manage our website, systems and applications, statistics and business development, cf. GDPR, Article 6(1)(f). The data subjects. Five years after the latest project for the customer has been completed.

Personal data may be disclosed to other Implement group companies in accordance with the terms laid down in Implement’s intragroup data processing agreement.

Personal data may also de disclosed to subcontractors who are directly involved in the project for the customer.

Implement Consulting Group P/S, CBR: 32767788 (Denmark).

Implement Consulting Group AG (Zurich, Switzerland) for marketing activities aimed at data subjects in Switzerland.

Marketing activities, including customer relation management (CRM) system. Customers and potential customers, including their employees. Non-sensitive personal data, i.e. name, position, contact details Processing is necessary in order for Implement to pursue its legitimate interests in being able to manage and strengthen customer relations, developing our business and services (e.g. identifying customer needs and improvements in service delivery) cf. GDPR, Article 6(1)(f). Customers, including customers’ employees and public sources such as cvr.dk, biq.dk, greens.dk, linkedIn.com As long as data are relevant to Implement from a commercial perspective or until the data subject requests a deletion of the data. Personal data may be disclosed to other Implement group companies in accordance with the terms laid down in Implement’s intragroup data processing agreement.
Implement Consulting Group P/S, CBR: 32767788 (Denmark). Management of Implement’s whistleblower system.
  • Customers
  • Customers’ employees,
  • Implement’s partners or employees,
  • Business partners
  • Business partners’ employees
Name, contact details, personal data contained in the report regardless of whether it is an internal or external reporting channel. Processing is necessary in order for Implement to pursue its legitimate interests in being able to investigate and handle irregularities, improper behaviour, criminal offences etc., cf. GDPR, Article 6(1)(f).

Persons reporting incidents through the whistleblower system.

Internal and external persons who have information on the reported incident.

Reports beyond the scope of the whistleblower system will be erased as soon as the investigation has been completed.

Reports giving rise to action will be erased five years after the matter has been finally resolved.

Implement may disclose personal data to external legal counsel. In case of criminal offences, personal data may be disclosed to the police. Finally, Implement will disclose to public authorities where we are under a legal obligation to do so.

The company which has entered into a contract with the supplier or business partner. Management of suppliers and business partners. Suppliers and business partners, including their employees. Non-sensitive personal data, i.e. name, position, contact details. Processing of personal data is necessary for the performance of contracts with the supplier or business partner, cf. GDPR, Article 6(1)(b). Processing is also necessary in order for Implement to pursue its legitimate interests in being able to evaluate the business relationship, cf. GDPR, Article 6(1)(f). The data subjects. As long as data are relevant to Implement from a commercial perspective or until the data subject requests deletion of the data. Implement does not disclose any personal data to third parties, unless we are under a legal obligation to do so.
The company which organises the course. Management of courses at Implement Learning Institute (ILI). Course participants, course instructors. Non-sensitive personal data, i.e. name, position, contact details. Processing of personal data is necessary for the performance of contracts with participants, cf. GDPR, Article 6(1)(b). Processing is also necessary in order for Implement to pursue its legitimate interests in being able to evaluate the course, cf. GDPR, Article 6(1)(f). The data subjects. Five years from the date on which the participant signed up for the course. Implement does not disclose any personal data to third parties unless we are under a legal obligation to do so.
The company which organises the event. Administration of events. Participants in events. Non-sensitive personal data, i.e. name, position, contact details. Processing of personal data is necessary for the performance of contracts with participants, cf. GDPR, Article 6(1)(b). Processing is also necessary in order for Implement to pursue its legitimate interests in being able to evaluate the event, cf. GDPR Article 6(1)(f). The data subjects. As long as data are relevant to Implement from a commercial perspective or until the data subject requests deletion of the data. Implement does not disclose any personal data to third parties unless we are under a legal obligation to do so.
The company to which the data subject has consented to receiving newsletters from. Administration of newsletters. Subscribers to newsletters. Non-sensitive personal data, i.e. name, position, contact details. Processing of personal data is necessary for the performance of contracts with participants, cf. GDPR Article 6(1)(b). Processing is also necessary in order for Implement to pursue its legitimate interests in being able to send the newsletter to the subscriber, cf. GDPR, Article 6(1)(f). The data subjects. Until the data subjects terminates the subscription. Implement does not disclose any personal data to third parties unless we are under a legal obligation to do so.
The company to whom a candidate has sent his/her application. Recruitment. The job applicant.

Non-sensitive personal data, i.e. name, position, contact details, educational and professional background, any other personal data which the applicant provides, references.

Personal data about criminal offences, including the applicant’s criminal record.

Processing of non-sensitive personal data is necessary in order for Implement to pursue its legitimate interests in being able to recruit applicants to positions at Implement Consulting Group, GDPR, Article 6(1)(f).

Personal data is processed where necessary to take steps at the request of the applicants prior to entering into a contract, cf. GDPR, Article 6(1)(b).

We process personal data collected from references, provided that the applicant has consented to this, cf. GDPR, Article 6(1)(a).

We process personal data on criminal records if it is necessary for the purpose of a legitimate interest in ensuring that the applicant is suited for the position at Implement, cf. GDPR, Article 10, cf. Data Protection Act, Section 8(3).

The data subjects and any references (upon consent from the data subject).

Six months after the date on which the applicant was rejected.

If the applicant is employed by Implement, the processing of personal data will continue during the employment period.

 Implement does not disclose any personal data to third parties unless we are under a legal obligation to do so. 

Video surveillance

We process personal data about visitors obtained from video surveillance for security purposes. The processing of personal data is necessary to pursue our legitimate interest in ensuring a high level of security, cf. GDPR, Article 6(1)(f) and GDPR, Article 10, cf. Data Protection Act, Section 8(3).

In case we process sensitive personal data, it is necessary for the establishment, exercise or defence of legal claims, cf. GDPR, Article 9(2)(f). In the areas where we use video surveillance, we inform visitors about such surveillance in accordance with the Danish TV Surveillance Act, Section 3(1). All recordings are stored securely and are only viewed if there are reasonable grounds for doing so, e.g. in case of an incident, and in such case only by selected persons. The recordings are automatically overwritten after five days, unless a problem is identified which requires investigation.

Personal data will only be disclosed to the police when an issue requiring investigation (e.g. theft) has occurred.

Use of cookies on our websites

We use cookies on our websites in order to optimise the user experience.

You can read more about the cookies we use here.

Security of processing

Data security is a high priority at Implement. We work seriously and professionally with information security, and we base our work on internationally recognised security standards. We have implemented security measures to ensure data protection of customer data, personal data and other confidential data. We conduct regular internal follow-ups in relation to the adequacy and compliance of policies and measures.

We occasionally use other third parties, such as subcontractors, in connection with the provision of our services. Such third parties may be granted access to personal data in order for them to be able to provide the agreed service. Implement enters into data protection agreements that are necessary in order to ensure that security is in place to protect data and comply with our data protection obligations.

Implement also uses sub-data processors as part of our day-to-day IT operations. This means that personal data are processed by Implement’s sub-data processors. These sub-data processors are located within the EU. There are data processing agreements in place between Implement and all sub-data processors to ensure that all processing takes place in accordance with Implement’s instructions and is subject to the necessary security requirements.

Your rights as a data subject

As a data subject, you have certain rights pursuant to the General Data Protection Regulation. Your rights may be summarised as follows:

  1. The right of access by the data subject. You have the right to gain access to the personal data concerning you that we process.
  2. The right to have incorrect personal data rectified. You have the right to have incorrect personal data about yourself rectified without undue delay.
  3. The right to have personal data erased. You have the right to have your personal data erased at an earlier point in time than when our ordinary erasure takes place, where appropriate.
  4. The right to restriction of data processing. You have the right to restrict our processing of your personal data, where appropriate. In such cases, we may only process your data with your consent or in some very specific situations as outlined in the General Data Protection Regulation.
  5. The right to object to personal data processing, if our processing is based on Article 6(1)(e) and (f). In such cases, we may only process your personal data if we are able to demonstrate compelling legitimate grounds for doing so.
  6. The right to data portability. You have the right to receive your personal data in a structured, commonly used and machine-readable format. You may also request that we transmit your personal data to another data controller without hindrance.

For further information on your rights as a data subject, please refer to the Danish Data Protection Agency’s website (www.datatilsynet.dk), where you will find further guidelines.

When we process personal data based on your consent, you have the right to withdraw your consent at any time. Please contact us to withdraw consent for our processing of your personal data.

Changes to this data protection policy

We acknowledge that transparency is an ongoing responsibility. Therefore, we will continually review and update this data protection policy in order to ensure our compliance with applicable personal data law from time to time.

The data protection policy was updated in November 2018.

Contact

Please contact us if you would like to exercise your rights as described above, or if you have questions about our processing of your personal data or this data protection policy.

Implement Consulting Group
CBR: 32767788
Attn.: privacy@implement.dk
Strandvejen 54, 2900 Hellerup
Tel: +45 4586 7900

You may also get in touch with your contact person at Implement, who will be able to help you contact the right person.

Complaints

If you wish to complain about our processing of personal data, please send an email with the details of your complaint to privacy@implement.dk. We will handle your complaint and get back to you.

You also have the right to lodge a complaint about your rights and Implement’s processing of your personal data to the Danish Data Protection Agency. For further information on how to lodge a complaint to the Danish Data Protection Agency, please consult their website: www.datatilsynet.dk.

Statutory rules

The applicable statutory rules for Implement’s processing of your personal data may be found in:

  • The General Data Protection Regulation (GDPR)
  • The Danish Data Protection Act