Supplier Compliance Checker Documentation Confirm that you have the correct documents as required by GDPR. Q1 Are you the data controller, joint controller or data processor?Data controllerData processorJoint controllerIn most instances suppliers will be the processor. You must take instruction from the controller, ie the school Q2 Does your Privacy notice in the public domain explain how you process data for this product?YesNoPartlyDon't knowYour privacy document is a key asset to demonstrate your commitment to the GDPR principles. It should clearly explain how, where, what and for how long you process personal data. It should also explain complaints procedure in the event that there is a dispute in the way you process data. If you are a processor do you have a Privacy Notice to help Schools include this Processing in their Privacy Documentation Q3 Are your processing agreement and terms and conditions made available when the product is first used or available or for inspection on request?YesNoPartlyDon't knowIt is important that you are seen to be transparent and make agreements and policies available for inspection Q4.1 What is the url of your privacy notice?* Q4.2 What is the url of your processing agreement?* Q4.3 What is the url of your terms and conditions?* Q5-8 Do you have any of the following certifications?Information Security (such as ISO 27001)Quality Management (Such as ISO 9001)Personal Information Management System (such as ISO 27701Security RFI (Request for Information, Self-certification)Any other security certifications? Please stateThis is asking suppliers to share their qualifications which demonstrate their competence. It is important for you to demonstrate your commitment to data security by gaining recognised certifications Q9 How long do you store data?*As defined in our processing agreementsAs defined by the data controllerAs long as it is neededIt is kept indefinitelyAll organisations which handle personal data must say how long they store personal data. If you are a processor the controller should tell you how long this should be. If you are the controller or joint controller you should only keep data as long as it is needed Q10 Deleting personal data - If you are a data processor which of the following do you do?Delete data on request of the data subject Delete data as instructed by the data controller Delete data when you believe that it is no longer requiredIf you are the processor you must delete data on request of the controller. The data subject cannot ask you to do this in case the controller has a legitimate reason to keep it. Q11 Disposal of physical records: paper, magnetic, optical or similar - Do you use a specialist secure paper disposal to dispose of all sensitive data?YesNoPartlyDon't knowAll organisations which handle personal data must say how long they store personal data. If you are a processor the controller should tell you how long this should be. If you are the controller or joint controller you should only keep data as long as it is needed Q12 Disposal of digital records: secure erasure - Are the records you hold and process are labelled and subject to automated purge after their designated retention period?YesNoPartlyDon't knowPurging stale data is a key responsibility. Where data is held and processed by any organisation, it must ensure that processes and fail-safes are in place to purge data that is no longer needed Q13 Declaration in Privacy Notice - Is there a statement of deletion for end of life records (such as emails, files, database records) which appears in your privacy statement.YesNoPartlyDon't knowThis should be included in your Privacy Statement for records for which you are the data controller Q14 Do you handle any of the following data?Select all applicableRacial or ethnic origin Political opinionsReligious or philosophical beliefsTrade union membershipGenetic dataBiometric data (where used for identification purposes) Health dataData concerning a person’s sex lifeData concerning a person’s sexual orientationThese are special category data defined within the GDPR.It is important that you recognise that you are processing special category data and you publish what steps you take to keep it safe Q15 Can you confirm that you only process minimal data?YesNoPartlyDon't knowOnly the data that is needed for the purpose you are processing data should be used. In the past data is collected 'just in case' it is needed. This can no longer happen. Q16 Can you confirm that you control access to the data you process? Staff should be granted access only as needed.YesNoPartlyDon't knowAccess control is essential. Whether you are the controller or processor, data subjects must be confident that limited staff have access to their information. Q17 Can you confirm that you the data in your care is encrypted (at rest and in transit)?YesNoPartlyDon't knowIt goes without saying all personal data must be encrypted and special category data needs stronger encryption. Q18 Can you confirm that you support the controller to allow data subjects to exercise their rights?YesNoPartlyDon't knowThis is central to all that is done. Upholding the rights and freedoms of data subjects is paramount in any data protection strategy. A controller will not use a processor unless they are confident that their data subjects rights are upheld. Q19 List all the sub-processors you use for this product. Include: the task they carry out, country of their registered address, country where the data is stored and processedUnless you host your own servers and carry out all activitity 'in house' sub-processors will be used. It is the processor's duty to ensure that if data is processed elsewhere the correct agreements and guarantees are in place to safeguard the data. Controllers should be asking about sub-processors and their presence should be recognised. Q20 Do you have in place with all of your sub-processors data processing agreements, which guarantee at least the same level of protection to the data subjects that you agree with the school?YesNoPartlyDon't know Q21 Does any processing happen outside of the EEA? (storage or transfers)YesNoData stored/processed outside the EU may carry high risk and treated with caution Q22 Have you undertaken Transfer Impact Assessments (aka Transfer Risk Assessments) for any transfers to outside of the EEA?YesNoPartlyThe Schrems II decision has a major impact on any data transferred to outside the EEA. Special safeguards need to be put in place where that does happen.SubmitReset