KIA MOTORS BULGARIA – SOFIA LTD

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PERSONAL DATA PROTECTION POLICY

1. Objective and scope
KIA MOTORS BULGARIA – SOFIA LTD, hereinafter referred to as the “Company”, strives to comply with applicable laws and regulations related to Personal Data protection in countries where the Company operates. This Policy sets forth the basic principles by which the Company processes the personal data of consumers, customers, suppliers, business partners, employees and other individuals, and indicates the responsibilities of its business departments and employees while processing personal data.
This Policy applies to the Company and its directly or indirectly controlled wholly-owned subsidiaries conducting business within the European Economic Area (EEA) or processing the personal data of data subjects within EEA.
The users of this document are all employees, permanent or temporary, and all contractors working on behalf of The Company.

 

2. Basic Principles Regarding Personal Data Processing
The data protection principles outline the basic responsibilities for organisations handling personal data. Article 5(2) of the GDPR stipulates that “the controller shall be responsible for, and be able to demonstrate, compliance with the principles.”


2.1. Lawfulness, Fairness and Transparency
Personal data must be processed lawfully, fairly and in a transparent manner in relation to the data subject.


2.2. Purpose Limitation
Personal data must be collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes.


2.3. Data Minimization
Personal data must be adequate, relevant, and limited to what is necessary in relation to the purposes for which they are processed. The Company must apply anonymization or pseudonymization to personal data if possible to reduce the risks to the data subjects concerned.


2.4. Accuracy
Personal data must be accurate and, where necessary, kept up to date; reasonable steps must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified in a timely manner.


2.5. Storage Period Limitation
Personal data must be kept for no longer than is necessary for the purposes for which the personal data are processed.


2.6. Integrity and confidentiality
Taking into account the state of technology and other available security measures, the implementation cost, and likelihood and severity of personal data risks, the Company must use appropriate technical or organizational measures to process Personal Data in a manner that ensures appropriate security of personal data, including protection against accidental or unlawful destruction, loss, alternation, unauthorized access to, or disclosure.


2.7. Accountability
Data controllers must be responsible for and be able to demonstrate compliance with the principles outlined above.

 

3. Building Data Protection in Business Activities
In order to demonstrate compliance with the principles of data protection, an organisation should build data protection into its business activities.


3.1. Notification to Data Subjects
See the Fair Processing Guidelines section


3.2. Data Subject’s Choice and Consent
See the Fair Processing Guidelines section


3.3. Collection
The Company must strive to collect the least amount of personal data possible. If personal data is collected from a third party, Data Protection Responsible person must ensure that the personal data is collected lawfully.


3.4. Use, Retention, and Disposal
The purposes, methods, storage limitation and retention period of personal data must be consistent with the information contained in the Privacy Notice. The Company must maintain the accuracy, integrity, confidentiality and relevance of personal data based on the processing purpose. Adequate security mechanisms designed to protect personal data must be used to prevent personal data from being stolen, misused, or abused, and prevent personal data breaches. Data Protection Responsible person is responsible for compliance with the requirements listed in this section.


3.5. Disclosure to Third Parties
Whenever the Company uses a third-party supplier or business partner to process personal data on its behalf, Data Protection Responsible person must ensure that this processor will provide security measures to safeguard personal data that are appropriate to the associated risks. For this purpose, the Processor GDPR Compliance Questionnaire must be used.
The Company must contractually require the supplier or business partner to provide the same level of data protection. The supplier or business partner must only process personal data to carry out its contractual obligations towards the Company or upon the instructions of the Company and not for any other purposes. When the Company processes personal data jointly with an independent third party, the Company must explicitly specify its respective responsibilities of and the third party in the relevant contract or any other legal binding document, such as the Supplier Data Processing Agreement.


3.6. Rights of Access by Data Subjects
When acting as a data controller, Data Protection Responsible person is responsible to provide data subjects with a reasonable access mechanism to enable them to access their personal data, and must allow them to update, rectify, erase, or transmit their Personal Data, if appropriate or required by law. The access mechanism will be further detailed in the Data Subject Access Request Procedure.


3.7. Data Portability
Data Subjects have the right to receive, upon request, a copy of the data they provided to us in a structured format and to transmit those data to another controller, for free. Data Protection Responsible person is responsible to ensure that such requests are processed within one month, are not excessive and do not affect the rights to personal data of other individuals.


3.8. Right to be Forgotten
Upon request, Data Subjects have the right to obtain from the Company the erasure of its personal data. When the Company is acting as a Controller, Data Protection Responsible person must take necessary actions (including technical measures) to inform the third-parties who use or process that data to comply with the request.

 

4. Fair Processing Guidelines
Personal data must only be processed when explicitly authorised by Data Protection Responsible person. The Company must decide whether to perform the Data Protection Impact Assessment for each data processing activity according to the Data Protection Impact Assessment Guidelines.


4.1. Notices to Data Subjects
At the time of collection or before collecting personal data for any kind of processing activities including but not limited to selling products, services, or marketing activities, Data Protection Responsible person is responsible to properly inform data subjects of the following: the types of personal data collected, the purposes of the processing, processing methods, the data subjects’ rights with respect to their personal data, the retention period, potential international data transfers, if data will be shared with third parties and the Company’s security measures to protect personal data. This information is provided through Privacy Notice.
If your company has multiple data processing activities, you will need to develop different notices which will differ depending on the processing activity and the categories of personal data collected – for example, one Notice might be written for mailing purposes, and a different one for shipping purposes.
Where personal data is being shared with a third party, Data Protection Responsible person must ensure that data subjects have been notified of this through a Privacy Notice.
Where personal data is being transferred to a third country according to Cross Border Data Transfer Policy, the Privacy Notice should reflect this and clearly state to where, and to which entity personal data is being transferred.
Where sensitive personal data is being collected, the Data Protection Responsible person must make sure that the Privacy Notice explicitly states the purpose for which this sensitive personal data is being collected.


4.2. Obtaining Consents
Whenever personal data processing is based on the data subject's consent, or other lawful grounds, Data Protection Responsible person is responsible for retaining a record of such consent. Data Protection Responsible person is responsible for providing data subjects with options to provide the consent and must inform and ensure that their consent (whenever consent is used as the lawful ground for processing) can be withdrawn at any time.
Where collection of personal data relates to a child under the age of 16, Data Protection Responsible person must ensure that parental consent is given prior to the collection using the Parental Consent Form.
When requests to correct, amend or destroy personal data records, Data Protection Responsible person must ensure that these requests are handled within a reasonable time frame. Data Protection Responsible person must also record the requests and keep a log of these.
Personal data must only be processed for the purpose for which they were originally collected. In the event that the Company wants to process collected personal data for another purpose, the Company must seek the consent of its data subjects in clear and concise writing. Any such request should include the original purpose for which data was collected, and also the new, or additional, purpose(s). The request must also include the reason for the change in purpose(s). The Data Protection Responsible person is responsible for complying with the rules in this paragraph.
Now and in the future, The Data Protection Responsible person must ensure that collection methods are compliant with relevant law, good practices and industry standards.
Data Protection Responsible person is responsible for creating and maintaining a Register of the Privacy Notices.


5. Organization and Responsibilities
The responsibility for ensuring appropriate personal data processing lies with everyone who works for or with the Company and has access to personal data processed by the Company.
The key areas of responsibilities for processing personal data lie with the following organisational roles:
The Board of directors makes decisions about, and approves the Company’s general strategies on personal data protection.
The Data Protection Responsible person is responsible for managing the personal data protection program and is responsible for the development and promotion of end-to-end personal data protection policies.
The Legal officer monitors and analyses personal data laws and changes to regulations, develops compliance requirements, and assists business departments in achieving their Personal data goals.
The IT Manager, is responsible for:
Ensuring all systems, services and equipment used for storing data meet acceptable security standards.
Performing regular checks and scans to ensure security hardware and software is functioning properly.
The Marketing Manager, is responsible for:
Approving any data protection statements attached to communications such as emails and letters.
Addressing any data protection queries from journalists or media outlets like newspapers.
Where necessary, working with the Data Protection Officer to ensure marketing initiatives abide by data protection principles.
The Human Resources Manager is responsible for:
Improving all employees' awareness of user personal data protection.
Organizing Personal data protection expertise and awareness training for employees working with personal data.
End-to-end employee personal data protection. It must ensure that employees' personal data is processed based on the employer's legitimate business purposes and necessity.
The Procurement Manager is responsible for passing on personal data protection responsibilities to suppliers, and improving suppliers' awareness levels of personal data protection as well as flow down personal data requirements to any third party a supplier they are using. The Procurement Department must ensure that the Company reserves a right to audit suppliers.

 

6. Response to Personal Data Breach Incidents
When the Company learns of a suspected or actual personal data breach, Data Protection Responsible person must perform an internal investigation and take appropriate remedial measures in a timely manner, according to the Data Breach Policy. Where there is any risk to the rights and freedoms of data subjects, the Company must notify the relevant data protection authorities without undue delay and, when possible, within 72 hours.

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