GDPR at BeyondTrust

The EU General Data Protection Regulation and the UK General Data Protection Regulation (together, the “GDPR”):

1. Strengthens the rights of individuals regarding their personal data; and
2. Introduces obligations for organizations collecting and processing personal data of EU and UK residents.

At BeyondTrust, we are committed to:

• Ensure the security and protection of the personal data we process; and
• Provide a compliant and consistent approach to individuals’ data protection.

We are dedicated to safeguarding the personal data under our remit and maintaining a data protection regime that is effective and fit for purpose. Our programme for GDPR compliance is summarised in this statement.

We commit to collect and process personal data according to the following principles:

• Lawfulness, Fairness, and Transparency: Your data will be processed lawfully, fairly and in a transparent manner.
• Purpose Limitation: We will collect your data only for valid purposes and we will not further process it in a manner that is incompatible with those purposes.
• Data Minimization: We will process only data that is adequate, relevant, and limited to what is necessary in relation to our purposes.
• Accuracy: We will keep your data accurate and kept up to date. If we see that your data is not accurate, we will ensure that it is cancelled or corrected as soon as possible.
• Storage Limitation: We will keep your data for no longer than is necessary for the purposes we told you about.
• Integrity & Confidentiality: We will keep your data secure by using appropriate technical and/or organizational measures.
• Accountability: We commit to being able to demonstrate that we comply with the above principles.

Our ongoing compliance programme includes:

Information Audit: Periodically carrying out a company-wide information audit to identify and assess what personal data we hold, where it comes from, how and why it is processed and if and to whom it is disclosed.

Policies & Procedures: Reviewing and maintaining our data protection policies and procedures to meet the requirements and standards of the GDPR and any relevant data protection laws, including:

1. Legal Basis for Processing: We review our processing activities to identify the legal basis for processing and ensure that each basis is appropriate for the activity it relates to. We also maintain records of our processing activities, ensuring that our obligations under Article 30 of the GDPR and other correspondent privacy laws are met.
2. Privacy Notice/Policy: We regularly revise our Privacy Notice(s) to comply with the GDPR, ensuring that all individuals whose personal data we process have been informed of why we need it, how it is used, what their rights are, who the information is disclosed to and what safeguarding measures are in place to protect their information.
3. Obtaining Consent: We confirm that our consent mechanisms for obtaining personal data ensure that individuals understand what they are providing, why and how we use it and giving clear, defined ways to consent to us processing their information. We have stringent processes for recording consent, making sure that we can evidence an affirmative opt-in, along with time and date records. We also provide and an easy to see and access way to withdraw consent at any time.
4. Direct Marketing: We perform direct marketing activities in line with clear opt-in mechanisms for marketing subscriptions, as well as a clear notice and method for opting out and providing unsubscribe features on all subsequent marketing materials.
5. Data Protection Impact Assessments (DPIA): In the event that we process personal data that is considered high risk, involves large scale processing or includes special category/criminal conviction data, we have developed stringent procedures and assessment templates for carrying out impact assessments that comply fully with the GDPR’s Article 35 requirements. We have implemented documentation processes that record each assessment, allow us to rate the risk posed by the processing activity and implement mitigating measures to reduce the risk posed to the data subject(s).
6. Processor Agreements: Where we use any third-party to process personal data on our behalf (i.e. Payroll, Recruitment, Hosting, etc.), we have compliant Data Processor Agreements and due diligence procedures for ensuring that they (as well as we), meet and understand their/our GDPR obligations.
7. Accountability: Accountability and governance measures are in place to ensure that we understand and adequately disseminate and evidence our obligations and responsibilities; with a dedicated focus on privacy by design and the rights of individuals.
8. Data Retention & Erasure: Our retention policy and schedule ensure that we meet the ‘data minimisation’ and ‘storage limitation’ principles and that personal data is stored, archived and destroyed compliantly and ethically. We have dedicated erasure procedures in place to meet the ‘Right to Erasure’ obligation and are aware of when this and other data subject’s rights apply; along with any exemptions, response timeframes and notification responsibilities.
9. Data Breaches: Our breach procedures ensure that we have safeguards and measures in place to identify, assess, investigate and report any personal data breach at the earliest possible time. Our procedures are robust and have been disseminated to all employees, making them aware of the reporting lines and steps to follow.
10. International Data Transfers: Where BeyondTrust stores or transfers personal data outside the EEA, we have robust procedures and safeguarding measures in place to secure, encrypt and maintain the integrity of the data. Our procedures include a continual review of the countries with adequacy decisions, as well as standard data protection clauses or approved codes of conduct for those countries without. We carry out strict due diligence checks with all recipients of personal data to assess and verify that they have appropriate safeguards in place to protect the data, ensure enforceable data subject rights and have effective legal remedies for data subjects where applicable.
11. Subject Access Request (SAR): Our SAR procedures accommodate the applicable timeframe for providing the requested information. Our procedures detail how to verify the data subject, what steps to take for processing an access request, what exemptions apply and a suite of response templates to ensure that communications with data subjects are compliant, consistent and adequate.
12. Special Categories Data: Where we obtain and process any special category information, we do so in compliance with the Article 9 requirements and have high-level encryptions and protections on all such data. Special category data is only processed where necessary and where we have first identified the appropriate Article 9(2) condition.

In addition to the policies and procedures mentioned above, we provide easy to access information regarding an individual’s right to access any personal data that BeyondTrust processes about them and to request information about:

1. What personal data we hold about them
2. The purposes of the processing
3. The categories of personal data concerned
4. The recipients to whom the personal data has/will be disclosed
5. How long we intend to store the personal data
6. If we did not collect the data directly from them, information about the source
7. The right to have incomplete or inaccurate data about them corrected or completed and the process for requesting this
8. The right to request erasure of personal data (where applicable) or to restrict processing in accordance with data protection laws, as well as to object to any direct marketing from us and to be informed about any automated decision-making that we use
9. The right to lodge a complaint or seek judicial remedy and who to contact in such instances

BeyondTrust takes the privacy and security of individuals and their personal data seriously and takes reasonable measures and precautions to protect and secure the personal data that we process.

We have robust information security policies and procedures in place to protect personal data from unauthorised access, alteration, disclosure or destruction and have several layers of security measures, as described in further detail in our Trust Center.

BeyondTrust has a designated Data Protection Officer (DPO) and has appointed a data privacy team to maintain our GDPR programme. The team is responsible for promoting awareness of the GDPR across the organisation, assessing our GDPR readiness, identifying any gap areas and implementing the new policies, procedures and measures.

BeyondTrust understands that continuous employee awareness and understanding is vital to the continued compliance of the GDPR. We have implemented an ongoing employee training program on data and privacy protection.

If you have any questions about our GDPR programme, please contact our Data Protection Officer (DPO) at dataprotectionofficer@beyondtrust.com.

For additional information on how we process your personal data, see our Privacy Notice.