Data Protection Policy
Effective Date: March 12th, 2018
Updated: December 17th, 2021
99 WALL ST, SUITE 4255
NEW YORK 10005
This document governs the Data Protection policy
of our websites.
#IAA needs to collect and use certain personal data and
information about individuals. These individuals can include customers,
suppliers, business contacts, employees, and other people whom the organization
has a relationship with or may need to contact.
This policy describes how these personal data must be
collected, processed, and stored to meet data protection standards and comply
with the law.
The reason for this policy
This data protection policy explains how #IAA:
with data protection laws and follows good practice
the rights of employees, partners, customers, and contractors
how it stores and processes individuals data
protect personal data from the risks of data breach
Data protection laws
#IAA is committed to processing data in accordance
with its responsibilities under the General Data Protection Regulation (GDPR)
and other data protection and privacy laws. These data protection and privacy
laws describe how organizations must collect, process, and store personal
information. These rules apply regardless of whether data are stored
electronically, on paper, or in other formats. To comply with the law personal
information must be collected and used fairly, stored safely, and not disclosed
Article 5 of the GDPR requires that personal data will
a. processed lawfully, fairly, and transparently in relation
b. collected for specified, explicit, legitimate purposes
and not further processed in a manner that is incompatible with those purposes;
further processing for archiving purposes in the public interest, scientific or
historical research, or statistical purposes will be considered compatible with
the initial purposes
c. adequate, relevant, and limited to what is necessary in
relation to the purposes for which they are processed
d. accurate and, where necessary, kept up to date; every
reasonable step must be taken to make sure that personal data that are
inaccurate regarding the purposes for which they are processed, are immediately
erased or rectified
e. kept in a form which permits identification of data
subjects for no longer than is necessary for the purposes for which the
personal data are processed; personal data may be stored for longer periods
insofar as the personal data will be processed solely for archiving in the
public interest, scientific or historical research, or statistical purposes
subject to implementation of the appropriate technical and organizational
measures required by the GDPR in order to safeguard the rights and freedoms of
f. processed in a manner that ensures appropriate security
of the personal data, including protection against unauthorized or unlawful
processing; accidental loss, destruction, or damage; using appropriate
technical or organizational measures.
People, risks, responsibilities, and policy scope
This policy applies to:
head office of IAA
branches of IAA
employees of IAA
suppliers, contractors, and other people working on behalf of IAA
It applies to all data that the company holds relating to
identifiable individuals, even if that information technically falls outside
some privacy and data protection laws. This can include the following personal
- other personal
information about individuals.
Data protection risks
This policy helps to protect IAA from data security
of confidentiality, for example information being given out or
exposed without proper authorization
to give choice, for example, all individuals should be free to
choose how the company uses data relating to them
damage, for example, the company could suffer if unauthorized individuals successfully
gained access to sensitive data.
Everyone who works for or with IAA has some responsibility
for making sure that data are collected, stored, and processed appropriately. Everyone
who handles personal data must make sure that the data are handled and
processed in line with this policy and the principles of data protection.
General employee guidelines
only people able to access data covered by this policy should be those who
need it for their work.
should not be shared with others without appropriate authorization. When access
to and the sharing of confidential information is required, employees can
request it from their supervisors.
- IAA will
provide training to all employees to help them understand
their responsibilities when handling data and confidential information.
should keep all data secure by taking reasonable precautions and following
the guidelines below.
passwords must be used and should never be shared.
data should not be disclosed to unauthorized people within the company nor
should be regularly reviewed and updated if they are found to be out of
date. If no longer required, they should be deleted and disposed of using
appropriate security procedures.
should request help from their supervisors or a data protection officer if
they are unsure about any aspect of data protection procedures.
rules describe how and where personal data should be safely stored.
Questions about safely storing personal data can be directed to the IT
manager or data controller.
personal data are stored on paper, they should be kept in a secure place
where unauthorized people cannot see them.
guidelines also apply to personal data that are usually stored
electronically but have been printed out for some reason:
not required, the paper or files should be kept in a locked drawer, filing
cabinet, or environment.
and contractors should make sure that paper and printouts are not left
where unauthorized people could see them, such as in copiers or printers.
of personal data should be shredded and disposed of securely
when no longer needed.
data are stored electronically, they must be protected from unauthorized
access, accidental deletion, and malicious hacking attempts.
data should be protected by strong passwords that are changed regularly
and never shared among employees nor contractors.
personal data are stored on removable media such as a DVD, CD, or portable
drive, they should be kept locked away securely when not used.
data should only be stored on designated drives and servers and should
only be uploaded to approved and secure cloud computing services.
containing personal data should be situated in a secure location away from
general offices and visitor traffic.
data should be backed up frequently and securely. Backups should regularly
be tested in line with the company's standard backup procedures.
data should never be saved directly to laptops, portable drives, tablets,
nor smart phones.
computers and servers containing personal data should be protected by
approved firewall and security software.
Personal data use
When personal data are accessed, their use can be at the
greatest risk of theft, loss, or corruption:
working with personal data, employees, contractors, and others should make
sure that their computers are always password protected and locked when
data should not be shared with anyone who is not authorized to see them.
Unless encrypted, they should never be sent by email, as most email
communication is not secure.
must be encrypted before being transferred electronically. The IT manager
can explain how to send data to authorized external contacts.
data should never be transferred out of the European Union without
appropriate consent, binding corporate rules, compelling legitimate
interests, specific derogations, or other approved processes.
contractors, and others should not save copies of personal data to their
own computers or other devices. Always access and update the central copy
of any personal data.
Personal data accuracy
law requires IAA to take reasonable steps to make sure that personal data
are kept accurate and up to date.
more important it is that the personal data are accurate, the more effort IAA
should put into guaranteeing their accuracy.
- It is
the responsibility of all employees, contractors, and others who work with
personal data to take reasonable steps to keep personal data as accurate
and up to date as possible.
data will be held in as few places as necessary. Company employees and
contractors should not create unnecessary additional data sets.
employees and contractors should take every opportunity to make sure that
data are updated. For example, by confirming customers information when
- IAA will
make it easy for data subjects to update the information IAA holds about
them. As an example, by using the company website, Internet portal, or by
data should be updated when inaccuracies are discovered. For instance, if
a customer can no longer be reached on their stored telephone number, it
should be removed from the database.
- It is
the marketing managers responsibility to make sure that marketing
databases are checked and updated against industry suppression files
Subject access requests
All individuals who are the subjects of personal data
held by IAA are entitled to:
what information the company holds about them and why
- ask how
to gain access to it
how to keep it up to date
how the company is meeting its data protection obligations.
If an individual contacts the company requesting this
information, this is called a subject access request (SAR).
SARs from individuals should be made by email addressed to
the contact information at the top of this policy. The data controller can
supply a standard request form, although individuals do not have to use it.
The data controller will provide the relevant data within 30
days from receiving the request. The data controller will always verify the
identity of anyone making a subject access request before providing them with
Disclosing personal data for other reasons
In certain circumstances privacy laws allow personal data to
be disclosed to law enforcement agencies without the consent of the data
subject. Under these circumstances IAA will disclose the requested data.
However, the data controller will make sure that the request is legitimate and
seek assistance from legal counsel if necessary.
In the event of a breach of security leading to accidental
or unlawful destruction, loss, alteration, unauthorized disclosure of, or
access to personal data IAA will assess the risk to peoples rights and freedoms
and if required report this breach to the appropriate authority.
#IAA does its best to make sure that individuals are aware
that their data are being processed, and that they understand:
their personal data are being used
- how to
exercise their rights under the law.
The company has a comprehensive privacy notice explaining
how data relating to individuals are collected, processed, stored, shared, and
protected by the company.
This data protection policy notice is available on request.
A current version of this notice is also available on all company's websites.
If you have any questions about data protection policy, please contact us using
the information at the top of this privacy notice.