Data Protection Policy

Effective Date: March 12^th, 2018
Updated: December 17^th, 2021

Notice V3.15.7

INTERNATIONAL AFFILIATES ASSOCIATION

99 WALL ST, SUITE 4255

NEW YORK, NEW YORK 10005

(929) 341-0005

This document governs the Data Protection policy of our websites.

Introduction
#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:

complies with data protection laws and follows good practice
protects the rights of employees, partners, customers, and contractors
explains how it stores and processes individuals data
helps 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 unlawfully.

Article 5 of the GDPR requires that personal data will be:

a. processed lawfully, fairly, and transparently in relation to individuals

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 individuals

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:

the head office of IAA
all branches of IAA
all employees of IAA
all 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 data:

names of individuals
postal addresses
email addresses
telephone numbers
other personal information about individuals.

Data protection risks

This policy helps to protect IAA from data security risks, including:

breaches of confidentiality, for example information being given out or exposed without proper authorization
failing to give choice, for example, all individuals should be free to choose how the company uses data relating to them
reputational damage, for example, the company could suffer if unauthorized individuals successfully gained access to sensitive data.

Responsibilities

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

The only people able to access data covered by this policy should be those who need it for their work.
Data 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.
Employees should keep all data secure by taking reasonable precautions and following the guidelines below.
Strong passwords must be used and should never be shared.
Personal data should not be disclosed to unauthorized people within the company nor externally.
Data 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.
Employees should request help from their supervisors or a data protection officer if they are unsure about any aspect of data protection procedures.

Data storage

These 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.
When personal data are stored on paper, they should be kept in a secure place where unauthorized people cannot see them.
These guidelines also apply to personal data that are usually stored electronically but have been printed out for some reason:
When not required, the paper or files should be kept in a locked drawer, filing cabinet, or environment.
Employees and contractors should make sure that paper and printouts are not left where unauthorized people could see them, such as in copiers or printers.
Printouts of personal data should be shredded and disposed of securely when no longer needed.
When data are stored electronically, they must be protected from unauthorized access, accidental deletion, and malicious hacking attempts.
Personal data should be protected by strong passwords that are changed regularly and never shared among employees nor contractors.
If 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.
Personal data should only be stored on designated drives and servers and should only be uploaded to approved and secure cloud computing services.
Servers containing personal data should be situated in a secure location away from general offices and visitor traffic.
All data should be backed up frequently and securely. Backups should regularly be tested in line with the company's standard backup procedures.
Personal data should never be saved directly to laptops, portable drives, tablets, nor smart phones.
All 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:

when working with personal data, employees, contractors, and others should make sure that their computers are always password protected and locked when left unattended.
personal 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.
data must be encrypted before being transferred electronically. The IT manager can explain how to send data to authorized external contacts.
personal 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.
employees, 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

The law requires IAA to take reasonable steps to make sure that personal data are kept accurate and up to date.
The 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.
Personal data will be held in as few places as necessary. Company employees and contractors should not create unnecessary additional data sets.
Company employees and contractors should take every opportunity to make sure that data are updated. For example, by confirming customers information when they call.
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 phone.
Personal 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 yearly.

Subject access requests

All individuals who are the subjects of personal data held by IAA are entitled to:

ask what information the company holds about them and why
ask how to gain access to it
know how to keep it up to date
know 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 any information.

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.

Data Breach

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.

Providing information

#IAA does its best to make sure that individuals are aware that their data are being processed, and that they understand:

how 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.