|Norra Cards||means Norra Cards, a registered PMV in Denmark|
|GDPR||means the General Data Protection Regulation|
|Responsible person||means Femke Welmoed Barendsen|
|Register of Systems||means a register of all systems or contexts in which personal data is processed by Norra Cards|
|Datatilsynet||The Information Commission responsible for the GDPR in Denmark|
Norra Cards is committed to processing data in accordance with its responsibilities under the GDPR. Below you will find the European Legal Framework that guides the data policy of Norra Cards.
Article 5 of the GDPR requires that personal data shall be:
a. processed lawfully, fairly and in a transparent manner in relation to individuals;
b. collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;
c. adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
d. 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;
e. 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 insofar 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 organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals; and
f. processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.”
Data transmission and recording
On www.norracards.com particular information is collected about the geographical location (country-level) of the visitors, how they accessed the website (through the browser, or via third-party links) and which pages were visited. With Norra Cards, you only provide us with your information once you place an order.
The data is collected only for the purpose of statistical analysis and to establish the correct currency. A distinction is made between customers from Scandinavia and customers fro Eurozone countries (specifically the Netherlands, Germany and Belgium). The information cannot be traced back to specific individuals and is not merged with other data sources.
Use of personal data
Your personal data will only be collected when you: send an information request, place an order, opt-in for the Norra cards newsletter, or contact us in any other way. This concerns information that is voluntarily provided to us. Your personal information is used for administrative purposes and to communicate with you. Norra Cards does not receive any money from third party companies in exchange for your personal information. In fact, Norra Cards doesn’t share personal information with any third party.
- This policy applies to all personal data processed by Norra Cards.
- The Responsible Person shall take responsibility for Norra Cards’s ongoing compliance with this policy.
- This policy shall be reviewed at least annually.
- Norra Cards shall register with the Information Commissioner’s Office (Datainspektionen) as an organisation that processes personal data.
Lawful, fair and transparent processing
- To ensure its processing of data is lawful, fair and transparent, Norra Cards shall maintain a Register of Systems.
- The Register of Systems shall be reviewed at least annually.
- Individuals have the right to access their personal data and any such requests made to Norra Cards shall be dealt with in a timely manner.
- All data processed by Norra Cards must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests (see datainspektionen.se for more information)
- Norra Cards shall note the appropriate lawful basis in the Register of Systems.
- 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 Norra Cards’s systems.
- Norra Cards shall ensure that personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
- This means that Norra Cards will only collect information that is relevant for 1) ensuring that the placed order arrives in good shape and in good time, 2) ensuring that a contact request is answered.
- Norra Cards 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.
Archiving / removal
- To ensure that personal data is kept for no longer than necessary, Norra Cards 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, for how long, and why.
- Norra Cards shall ensure that personal data is stored securely using modern software that is kept-up-to-date.
- Access to personal data shall be limited to personnel who need access and appropriate security should be in place to avoid unauthorised sharing of information.
- When personal data is deleted this should be done safely such that the data is irrecoverable.
- Appropriate back-up and disaster recovery solutions shall be in place.
In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data, Norra Cards shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach to Datatilsynet in Denmark