1.2.   Scope

1.3.   Responsibilities

1.4.   Policy Compliance

1.5.   Data Privacy Principles

• Notice:  ChainSys shall provide data subjects with notice about how it collects, uses, retains, and discloses personal information about them.
• Choice and Consent:  ChainSys shall give data subjects the choices and obtain their consent regarding how it collects, uses, and discloses their personal information.
• Rights of Data subject:   ChainSys shall provide individuals with the right to control their personal information, which includes the right to access, modify, erase, restrict, transmit, or object to certain uses of their information and for withdrawal of earlier given consent to the notice.
• Collection:   ChainSys shall collect personal information from data subjects only for the purposes identified in the privacy notice / SoW /contract agreements and only to provide requested product or service.
• Use, Retention and Disposal:   ChainSys shall only use personal information that has been collected for the purposes identified in the privacy notice / SoW / contract agreements and in accordance with the consent that the data subject shall provide. ChainSys shall not retain personal information longer than is necessary to fulfil the purposes for which it was collected and to maintain reasonable business records. ChainSys shall dispose of the personal information once it has served its intended purpose or as specified by the data subject.
• Access:  ChainSys shall allow data subjects to make inquiries regarding the personal information about them, that ChainSys shall hold and, when appropriate, shall provide access to their personal information for review, and/or update.
• Disclosure to Third Parties: ChainSys shall disclose personal information to Third Parties / partner firms only for purposes identified in the privacy notice / SoW / contract agreements. ChainSys shall disclose personal information in a secure manner, with assurances of protection by those parties, according to the contracts, laws and other segments, and, where needed, with consent of the data subject.
• Obligations for Sub-processor:   Where a engages another processor for carrying out specific processing activities on behalf of ChainSys the same data protection obligations as set out in the contract or other legal act between ChainSys and the processor shall be imposed on the Sub processor by way of a contract or other legal act under Union or Member State law, in particular providing sufficient guarantees to implement appropriate technical and organisational measures in such a manner that the processing will meet the requirements of GDPR. Where the Sub-processor fails to fulfil its data protection obligations, the initial processor shall remain fully liable to ChainSys for the performance of that Sub-processor's obligations.
• Access:  ChainSys shall allow data subjects to make inquiries regarding the personal information about them, that ChainSys shall hold and, when appropriate, shall provide access to their personal information for review, and/or update.
• Security for Privacy:   ChainSys shall protect personal information from un authorized access, data leakage and misuse.
• Quality:   ChainSys shall take steps to ensure that personal information in its records is accurate and relevant to the purposes for which it was collected.
• Monitoring and Enforcement: ChainSys shall monitor compliance with its privacy policies, both internally and with Third Parties, and establish the processes to address inquiries, complaints, and disputes.

1.6.   Notice

Privacy notices may include:

• the organization's operating jurisdictions: Third Parties involved; business segments and affiliates; lines of business; locations.
• types of personal information collected; sources of information; who is collecting the personal information, including contact information.
• the purpose of collecting the personal information.
• assurance that the personal information will be used only for the purpose identified in the notice and only if the implicit and / or explicit consent is provided unless a law or regulation specifically requires otherwise.
• any choices the data subject have regarding the use or disclosure of the information; the process and data subject shall follow to exercise the choices.
• the process for a data subject to change contact preferences and ways in which the consent is obtained.
• collection process and how the information is collected; how the information is used including any onward transfer to Third Parties.
• retention and disposal process for personal information; assurance that the personal information to be retained only if necessary to fulfil the stated purposes, or for a period specifically required by law or regulation and will be disposed-off securely or made anonymous post the identified purpose is completed.  process of accessing personal information; the costs associated for accessing personal information (if any); process to update / correct the personal information; the resolution of disagreements related to personal information; how the information is protected from unauthorized access or use;
• how users will be notified of any changes made to privacy notice;
• disclosure process for Third Parties; the assurance that the personal information is disclosed to Third Parties only for the purpose identified; the remedial actions in place for any misuse of personal information by the Third Parties.
• Security measures in place to protect the personal information; ways of maintaining quality of personal information.
• monitoring and enforcement mechanisms in place; description of the complaint channels available to data subjects; how the internal personnel, key stakeholders and the customers can contact the Company related to any privacy complaints or breaches; relevant contact information and / or other reporting methods through which the complaints and/or breaches could be registered
• Consequences of not providing the requested information.

1.7.   Choice and consent

Privacy notices may include:

• ChainSys shall establish systems for the collection and documentation of data subject consents to the collection, processing, and/or transfer of personal data.
• Data subjects shall be informed about the choices available to them with respect to the collection, use, and disclosure of personal information.
• Consent shall be obtained (in writing or electronically) from the data subjects before or at the time of collecting personal information or as soon as it is practical thereafter.
• The changes to a data subject’s preferences shall be managed and documented. Consent or withdrawal of consent shall be documented appropriately.
• The choices shall be implemented in a timely fashion and respected. If personal information is to be used for purposes not identified in the notice / SoW / contract agreements at the time of collection, the new purpose shall be documented, the data subject shall be notified, and consent shall be obtained prior to such new use or purpose. The data subject shall be notified if the data collected is used for marketing purposes, advertisements, etc.
• ChainSys shall review the privacy policies of the Third Parties and types of consent of Third Parties before accepting personal information from Third-Party data sources.

1.8.   Collection of Personal Information

• Personal information shall not be collected unless either of the following is fulfilled:
• • the data subject has provided a valid, informed and free consent;
  • processing is necessary for the performance of a contract to which the data subject is a party or in order to take steps at the request of the data subject prior to entering into a contract;
  • processing is necessary for compliance with the organizations legal obligation;
  • processing is necessary in order to protect the vital interests of the data subject; or
  • processing is necessary for the performance of a task carried out in the public interest
• Data subjects shall not be required to provide more personal information than is necessary for the provision of the product or service that data subject has requested or authorized. If any data not needed for providing a service or product is requested, such fields shall be clearly labelled as optional. Collection of personal information shall be avoided or limited when reasonably possible.
• Personal information shall be de-identified when the purposes of data collection can be achieved without personally identifiable information, at reasonable cost.
• When using vendors to collect personal information on the behalf of ChainSys, it shall ensure that the vendors comply with the privacy requirements of ChainSys as defined in this Policy.
• ChainSys shall at minimum, annually review and monitor the information collected, the consent obtained and the notice / SoW / contract agreement identifying the purpose.
• The project team/support function shall obtain approval from the IT Security team before adopting the new methods for collecting personal information electronically.
• ChainSys shall review the privacy policies and collection methods of Third-Parties before accepting personal information from Third-Party data sources.

1.9.   Use, Retention and Disposal

• Personal information shall be retained for as long as necessary for business purposes identified in the notice / SoW / contract agreements at the time of collection or subsequently authorized by the data subjects.
• When the use of personal information is no longer necessary for business purposes, a method shall be in place to ensure that the information is destroyed in a manner sufficient to prevent unauthorized access to that information or is de-identified in a manner sufficient to make the data non-personally identifiable.
• ChainSys shall have a documented process to communicate changes in retention periods of personal information required by the business to the data subjects who are authorized to request those changes.
• Personal information shall be erased if their storage violates any of the data protection rules or if knowledge of the data is no longer required by ChainSys or for the benefit of the data subject.  Additionally, ChainSys has the right to retain the personnel information for legal and regulatory purpose and as per applicable data privacy laws.
• ChainSys shall perform an internal audit on an annual basis to ensure that personal information collected is used, retained and disposed-off in compliance with the organization’s data privacy policy.

1.10.   Access

• Data subjects shall be entitled to obtain the details about their own personal information upon a request made and set forth in writing. ChainSys shall provide its response to a request within 72 hours of receipt of written request.
• The data subjects shall have the right to require ChainSys to correct or supplement erroneous, misleading, outdated, or incomplete personal information.
• Requests for access to or rectification of personal information shall be directed at the data subject’s option, to the manager of the projects team or support function responsible for the personal information.
• The privacy coordinators shall record and document each access request as it is received, and the corresponding action taken.
• ChainSys shall provide personal information to the data subjects in a plain simple format which is understandable (not in any code format).

1.11.   Disclosure to Third Parties

• Personal information of data subjects may be disclosed to the Third Parties / partner firms only for reasons consistent with the purposes identified in the notice / SoW / contract agreements or other purposes authorized by law.
• ChainSys shall notify the data subjects prior to disclosing personal information to Third Parties / partner firms for purposes not previously identified in the notice / SoW / contract agreements
• ChainSys shall communicate the privacy practices, procedures and the requirements for data privacy and protection to the Third Parties / partner firms.
• The Third Parties shall sign a NDA (Non-Disclosure Agreement) with ChainSys before any personal information is disclosed to the Third Parties partner firms. The NDA shall include the terms on non-disclosure of customer information.

1.12.   Security

• Information asset labelling and handling guidelines shall include controls specific to the storage, retention and transfer of personal information.
• Management shall establish procedures that maintain the logical and physical security of personal information.
• Management shall establish procedures that ensure protection of personal information against accidental disclosure due to natural disasters and environmental hazards.
• Incident response protocols are established and maintained in order to deal with incidents concerning personal data or privacy practices.
• Individuals noticing or becoming aware of any breach of personal data shall notify

1.13.   Quality

• For this purpose, the data privacy officer and privacy coordinators shall have systems and procedures in place to ensure that personal information collected is accurate and complete for the business purposes for which it is to be used.
• ChainSys shall perform an annual assessment on the personal information collected to check for accuracy, completeness and relevance of the personal information.

1.14.   Monitoring and enforcement

1.14.1   Dispute Resolution and Recourse

• The incident and breach management program includes a clear escalation path up to the executive management, legal counsel, and the board based on type and/or severity of the privacy incident/breach. It shall define a process to register all the incidents/complaints and queries related to data privacy
• ChainSys shall perform a periodic review of all the complaints related to data privacy to ensure that all the complaints are resolved in a timely manner and resolutions are documented and communicated to the data subjects.
• An escalation process for unresolved complaints and disputes which shall be designed and documented.
• Communication of privacy incident / breach reporting channels and the escalation matrix shall be provided to all the data subjects.

1.14.2   Dispute Resolution and Escalation Process for Employees

1.14.3   Dispute Resolution and Escalation Process for Customer / Third Party

1.14.4   Compliance Review

• The internal audit shall consist of the review of the following:
• • personal information collected from data subjects;
  • the purposes of the data collection and processing;
  • the actual uses of the data;
  • disclosures made about the purposes of the collection and use of such data;
  • the existence and scope of any data subject consents to such activities;
  • any legal obligations regarding the collection and processing of such data, and
  • the scope, sufficiency, and implementation status of security measures.
• The Privacy Review team shall document all the instances of non-compliance with privacy policies and procedures and report the same with the Privacy Management committee.
• The Data Privacy Officer along with Privacy Coordinators shall take actions on the findings from the internal audit and work on the recommendations for improvement of the privacy posture
• Any changes made to the policies shall be communicated to all the employees, the stakeholders, and the customers / clients.