On 25 May this year, the Regulation 2016/679 of the European Parliament and of the Council on the protection of natural persons in the processing of personal data and ensuring the free movement of such data (hereinafter referred to as the General Data Protection Regulation) is applied, which provides a number of new or more specific rights and obligations to the personal data controller, processor and data subject.
The General Data Protection Regulation will also apply to the processing of personal data by you as a customer of the service and by Modera Software AS as a Service Provider if we process personal data under your mandate within providing services to you based on a cooperation agreement between us.
Insofar as the Personal Data Protection Regulation requires that the personal data are processed on the basis of a contract or legislation between the controller and the processor that would regulate at least the issues provided for in Article 28 of the general regulation, it provides Modera Software AS as a processor a number of new or specified obligations, allows processing of personal data only on the basis of instructions of you as a controller, and prescribes more stringent liability and significant fines than today, it is important for Modera Software AS to ensure in timely manner whether any clarifications or amendments are necessary in the current agreements between Modera Software AS and you, or instructions given to us for performing works/providing services.
We assure you that Modera Software AS implements appropriate technical and organisational measures in such a manner that processing will meet the requirements of the Regulation and ensures the protection of the rights of the data subject. In order to fulfill the obligations arising from General Data Protection Regulation concerning the storage limitation of personal data, we have developed functionalities into our services, which allow you as a controller to choose and set the time limits for storing personal data. After the expiration of the time limit, data is automatically pseudonymised in a way that the personal data can no longer be attributed to a specific data subject by removing person`s names, contacts and other identificators.
We updated the Data Processing Agreement, which will regulate the minimum required issues and that we could conclude with you to fix the terms of the processing of personal data and involved rights and obligations, if appropriate for you. We will also ask for your position in terms of the relevant agreement within the abovementioned deadline.
In addition, we ask you to notify us within one month whether you consider other necessary changes in the works/services, terms of processing of personal data during performance of works/provision of services, or in other instructions to Modera Software AS in relation to the implementation of the new General Data Protection Regulation.
We thank you for the current pleasant cooperation and we are looking forward to cooperation also in the future.
Sincerely, Modera Software AS