ProductDive DATA PROTECTION POLICY  


ProductDive DATA PROTECTION POLICY  

Purpose: This policy applies to all personal data processed by ProductDive. The Data Controller shall take responsibility for ProductDive ongoing compliance with this policy.

Scope: This policy applies to all ProductDive employees, contractors, vendors, healthcare providers and agents.

Policy:

Data Protection Principles

ProductDive is committed to processing data in accordance with its responsibilities under the NDPR (Nigerian Data Protection Regulation).

With respect to the requirements of NDPR, personal data shall be:

  • Processed lawfully, fairly and in a transparent manner in relation to individuals.
  • Collected for specifies, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purpose; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be incompatible with the initial purposes.
  • Adequate, relevant, and limited to what is necessary in relation to the purposes for which they are processed.
  • Accurate and, where necessary, kept up to date; every reasonable step 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 without delay.
  • 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 in so far as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organizational measures required by the NDPR in order to safeguard the rights and freedoms of individuals
  • Processed in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction, or damage, using appropriate technical or organizational measures.

Data Processing Guidelines

The following guidelines are required by NDPR:

  • All data processed by ProductDive must be done on one of the following lawful bases, consent, contract, legal, obligation, vital interests, public task, or legitimate interests.
  • Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data.
  • Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent should be clearly available and systems should be in place to ensure such revocation is reflected accurately in ProductDive systems.

ProductDive Obligation

Data Minimization

  • ProductDive shall ensure that personal data are adequate, relevant, and limited to what is necessary in relation to the purposes for which they are processed.

Data Accuracy

  • ProductDive shall take reasonable steps to ensure personal data is accurate.
  • Where necessary for the lawful basis on which data is processed, steps shall be put in place to ensure that personal data is kept up to date.

Data Archiving/Removal

  • To ensure that personal data is kept for no longer than necessary, ProductDive shall put in place an archiving policy for each area in which personal data is processed and review this process annually.
  • The archiving policy shall consider what data should/must be retained, and how long and why.

Data Security

  • ProductDive shall ensure that personal data are stored securely using software that is kept up to date.
  • Access to personal data shall be limited to personnel who need access and appropriate security shall be in place to avoid unauthorized sharing of information.
  • When personal data is deleted, this should be done safely such that the data is irrecoverable.
  • Appropriate back up and data recovery solutions shall be in place.

Data Breach

  • In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data, ProductDive shall promptly assess the risk to people’s rights and freedom and if appropriate report breach to NITDA.

Enforcement:    Any employee found to have violated this policy may be subject to disciplinary action, up to and including termination of employment, and prosecution.

Thank you for choosing ProductDive. 

ProductDive Management Team.