SimplyDocs - Compliance Policies

Data Breach Notification Policy

1. Overview

SimplyDocs (Rise and Inspire Techlabs LLP) Data Breach Notification Policy (“Policy”) has been developed to provide for a reasonable and consistent response to data breach incidents involving Personal Data. The objective of this Policy is to ensure that SimplyDocs (Rise and Inspire Techlabs LLP) responds appropriately to data breaches and ensures that the appropriate notifications are made when necessary, in compliance with Applicable Laws. Compliance with this policy is in place to both minimize potential damages that could result from a data breach and to ensure that parties affected by a data breach are properly informed of how to protect themselves.

2. Definitions

  1. “Customer” means a third party that has entered into a binding, written agreement with SimplyDocs (Rise and Inspire Techlabs LLP) for the provision of Services.
  2. "Customer Personal Data" means any Personal Data Processed by SimplyDocs (Rise and Inspire Techlabs LLP) on behalf of a Customer pursuant to or in connection with a customer agreement;
  3. “Employee” means a natural person employed by SimplyDocs (Rise and Inspire Techlabs LLP) for wages or salary.
  4. "Employee Personal Data" means any Personal Data of natural persons Processed by SimplyDocs (Rise and Inspire Techlabs LLP) in connection with the performance of a contract of employment or for purposes of recruitment.
  5. "GDPR" means EU General Data Protection Regulation 2016/679;
  6. The terms, "Commission", "Controller", "Data Subject", "Member State", "Personal Data", "Personal Data Breach", "Processing" and "Supervisory Authority" shall have the same meaning as in the GDPR, and their cognate terms shall be construed accordingly.

3. Scope

This Policy applies in the event of a Personal Data Breach under Article 33 of the GDPR – Notification of a personal data breach to the supervisory authority – and Article 34 – Communication of a personal data breach to the data subject.

This Policy is applicable to all directors, partners, officers, and employees of SimplyDocs (Rise and Inspire Techlabs LLP) and any other individual or entity acting for or on behalf of SimplyDocs (Rise and Inspire Techlabs LLP), whether operating inside or outside India (collectively “Covered Persons”). Third parties, including but not limited to consultants, agents, intermediaries, and joint-venture partners, must be informed about this Policy and agree to comply with its tenets.

4. Data Breach Response Team

The following positions/individuals will constitute SimplyDocs (Rise and Inspire Techlabs LLP)’s Data Breach Response Team (or “Team”) for purposes of this Policy:

  • Data Control Officer
  • Security Representative
  • Support Representative
  • Technology Representative

5. Personal Data Breach

  1.  Customer Personal Data. SimplyDocs (Rise and Inspire Techlabs LLP) shall notify Controller without undue delay after becoming aware of a Personal Data Breach. Such notification shall at least: (i) describe the nature of the personal data breach including where possible, the categories and an approximate number of data subjects concerned and the categories and an approximate number of personal data records concerned; (ii) communicate the name and contact details of the data protection officer or another contact point where more information can be obtained; (iii) describe the likely consequences of the personal data breach; and (iv) describe the measures taken or proposed to be taken by the controller to address the personal data breach, including, where appropriate, measures to mitigate its possible adverse effects. Where, and in so far as, it is not possible to provide the information at the same time, the information may be provided in phases without undue further delay.
  2. Employee Personal Data.
    1. To the Data Subject. SimplyDocs (Rise and Inspire Techlabs LLP) shall, without undue delay and, where feasible, communicate the personal data breach to the data subject. The communication to the data subject referred to in paragraph 1 of this Article shall describe in clear and plain language the nature of the personal data breach and contain at least the information and measures referred to in points (b), (c) and (d) of Article 33(3).
    2. To the Supervisory Authority. SimplyDocs (Rise and Inspire Techlabs LLP) shall, without undue delay and, where feasible, not later than 72 hours after having become aware of it, notify the Personal Data Breach to the supervisory authority competent in accordance with Article 55. 2 Such notification shall at least: (i) describe the nature of the personal data breach including where possible, the categories and an approximate number of data subjects concerned and the categories and an approximate number of personal data records concerned; (ii) communicate the name and contact details of the data protection officer or another contact point where more information can be obtained; (iii) describe the likely consequences of the personal data breach; and (iv) describe the measures taken or proposed to be taken by the controller to address the personal data breach, including, where appropriate, measures to mitigate its possible adverse effects. Where the notification to the supervisory authority is not made within 72 hours, it shall be accompanied by reasons for the delay.

This policy is effective as of October 13, 2020.

Data Protection Policy

1. Data protection principles

SimplyDocs is committed to processing data in accordance with its responsibilities under the GDPR.

Article 5 of the GDPR requires that personal data shall be:

  1. processed lawfully, fairly and in a transparent manner in relation to individuals;
  2. 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;
  3. adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
  4. 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;
  5. 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
  6. 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.”

2. General provisions

  1. This policy applies to all personal data processed by the SimplyDocs (Rise and Inspire Techlabs LLP).
  2. The Responsible Person shall take responsibility for the SimplyDocs (Rise and Inspire Techlabs LLP) ongoing compliance with this policy.
  3. This policy shall be reviewed at least annually.

3. Lawful, fair and transparent processing

  1. To ensure its processing of data is lawful, fair and transparent, the SimplyDocs (Rise and Inspire Techlabs LLP) shall maintain a Register of Systems.
  2. The Register of Systems shall be reviewed at least annually.
  3. Individuals have the right to access their personal data and any such requests made to the SimplyDocs (Rise and Inspire Techlabs LLP) shall be dealt with in a timely manner.

4. Lawful purposes

  1. All data processed by the SimplyDocs (Rise and Inspire Techlabs LLP) must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests.
  2. The SimplyDocs (Rise and Inspire Techlabs LLP) shall note the appropriate lawful basis in the Register of Systems.
  3. Where consent is relied upon as a lawful basis for processing data, evidence of opt-in  consent shall be kept with the personal data.
  4. 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 the SimplyDocs. 

5. Data minimisation

  1. The SimplyDocs (Rise and Inspire Techlabs LLP) shall ensure that personal data are adequate, relevant and limited to what is necessary for relation to the purposes for which they are processed.

6. Accuracy

  1. The SimplyDocs (Rise and Inspire Techlabs LLP) shall take reasonable steps to ensure personal data is accurate.
  2. 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.

7. Archiving/removal

  1. To ensure that personal data is kept for no longer than necessary, the SimplyDocs shall put in place an archiving policy for each area in which personal data is processed and review this process annually.
  2. The archiving policy shall consider what data should/must be retained, for how long, and why.

8. Security

  1. The SimplyDocs (Rise and Inspire Techlabs LLP) shall ensure that personal data is stored securely using modern software that is kept-up-to-date. 
  2. 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.
  3. When personal data is deleted this should be done safely such that the data is irrecoverable.
  4. Appropriate back-up and disaster recovery solutions shall be in place.

9. Breach

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, the SimplyDocs (Rise and Inspire Techlabs LLP) shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach.