ActiveCollab & the General Data Protection Regulation

The General Data Protection Regulation (GDPR) is a new law establishing protections for the personal data of EU residents. The main goal of GDPR is to establish a standard for all organizations in the region when it comes to data privacy. Organizations (regardless of the organization’s global location) are required to develop certain procedures and safeguards that will regulate collecting, maintaining and using personal data of EU residents. In preparation for the GDPR, ActiveCollab has established a comprehensive compliance program and is committed to partnering with its customers and vendors to help them in their GDPR compliance efforts.

Privacy and safety of your data has always been a top priority for us. We are always aiming to raise the bar when it comes to delivering the best service possible, so we are constantly improving our product and website, so they are in compliance with GDPR and other relevant laws. We are looking forward to the impact GDPR is likely to have.

INFORMATION WE HOLD

We’ve performed extensive data mapping, which means we’ve identified all the personal data we process, their location, the way they are stored, used, deleted and archived. We’ve also identified who they are shared with and in which ways. We use a log management system so no employee can access data without authorization. This basically means we’ve performed a thorough analysis of all the data we store. All our employees have gone through applicable GDPR guidance trainings issued by regulatory authorities and we all keep learning about privacy by design and default. Maintaining the confidentiality and security of data is one of our ongoing priorities here at ActiveCollab. ActiveCollab’s data and information are hosted on servers in USA, Canada and France. We wrote more about data security in our Security Policy here. We extend our GDPR readiness by making sure all our third-party processors* located in US are also GDPR compliant.

COMMUNICATING PRIVACY INFORMATION

We are currently re-evaluating all of our processes, procedures, and complete documentation. We are updating all our processes so they are in compliance with GDPR. We are also updating our Privacy Policy, Security Policy and Terms of Service. This also means we will never automatically process your information without your consent.

LAWFUL BASIS FOR PROCESSING PERSONAL DATA AND CONSENT

Lawful basis means we need to have a legal reason to use your data. This reason has to comply with GDPR’s accountability requirements. It can be in accordance with our Terms of Service - which means we can use your data when we want to, for example, send you a bill, as defined in our contract; it can be your consent (you opted in) with notice - we told you what you were opting into; and it can be what GDPR calls legitimate interest (e.g. you are our customer, and we want to send you new products or functionalities related to what you currently have). If there is a legitimate interest, you always have a right to object further processing of your personal information.

BREACH MANAGEMENT

Your data matters. And GDPR is not only about data privacy, but also data protection. That’s why we’ve established and are implementing specific procedures designed to detect, report and investigate a personal data breach. In case of a data breach, we will promptly notify the regulators on our systems, our customers and end-users.

Organizational

• Data mapping and gap analysis - Done
• Update T&C - Done
• Data breach report compile - Done
• First training on GDPR compliance - In progress
• Periodic evaluation for organisational and technical measures - In progress

Policy

• Revise internal documents and policies - In progress
• Risk Assessment in accordance with ISO 31000 - Done
• Security incident response templates - In progress
• Regulate internal access to personal data - In progress
• Handling data responses to users - In progress

Technical

• Restrict access to servers from public locations - Done
• Use HTTPS for pages that handle sensitive information - Done
• Review and categorize currently stored data - Done
• Resolve security issues and implement recommendations - Done
• Anonymize IP addresses - In progress
• Revise stored data - In progress
• Unified platform access for company accounts - To be implemented
• Establishing Logging Policy - Done
• Anonymize data for staging - To be implemented

Product

• Implement user opt-in mechanism - In progress
• Log the consent - In progress
• General consent request - In progress
• Allow user revoke the right of using his data - In progress
• Re-ask the user for consent if necessary - In progress
• Add multi-factor authentication - In progress
• Data export tool - In progress
• Keep data a limited time after contract termination - In progress
• Obtain consent for previous collected data - To be implemented
• Expose/delete info for users - To be implemented
• Platform audit logs / update - To be implemented