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:
Also you can download the tables and the introduction above as PDF
Our processing activities for recruitment
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:
- The right of access by the data subject. You have the right to gain access to the personal data concerning you that we process.
- The right to have incorrect personal data rectified. You have the right to have incorrect personal data about yourself rectified without undue delay.
- 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.
- 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.
- 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.
- 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.
Your right to object and withdraw consent
As a data subject, you have the right to object to our processing of your personal data in certain situations, which are listed below:
Processing based on legitimate interests
You have the right to object to personal data processing, if our processing is based on Article 6(1)(e) and (f) of the GDPR. In such cases, we may only process your personal data, if we are able to demonstrate compelling legitimate grounds for doing so, which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims.
Processing for direct marketing purposes
You have the right to object to personal data processing, if we process the personal data for direct marketing purposes, cf. Article 21(2) of the GDPR, e.g. when registering you in our CRM system. In such cases the personal data will no longer be processed for such purposes.
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 March 2023.
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
CVR: 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