Secure disposal of personal information

Organization must document the retention periods for data sets and their possible archiving process (including archiving method, location or destruction). At the end of the retention period, the data must be archived or destroyed without delay in a secure manner.

When destroying data contained in data systems, the following points should be taken into account:

• suitable method of destruction (e.g. overwriting, cryptographic erasure ) is chosen taking into account the functional and statutory requirements
• the need to preserve evidence of data destruction is discussed
• when using third parties for data destruction, the requirement of evidence and the inclusion of destruction requirements in supplier contracts are discussed

The process of archiving or destroying data is defined in connection with the documentation, and the owner of the data is responsible for its implementation.

In the absence of specific situations as defined in the Data Protection Regulation, but one of the following criteria is met, the data subject has the right to have his or her personal data deleted:

• the processing is based on consent (and there is no other reason for processing) and the data subject withdraws her consent
• the data subject objects to the processing of his or her personal data for the purposes of direct marketing or otherwise exercises his or her right of objection and there is no valid reason for such processing
• personal data have been collected in connection with the provision of information society services

We are aware of the situations in which the "right to be forgotten" is realized in our actions. We have designed policies for these situations, which may include e.g.:

• the ways in which the data subject may request the deletion of data
• the means by which the identity of the sender of the request for information is verified
• persons assisting the contact person of the databank in processing the request
• the means by which data are securely and permanently deleted and the data subject is informed