1. Data protection principles
Haim Pharma Group Ltd. is committed to processing data in accordance with its responsibilities under the Privacy Law of Israel (DPA), and European General Data Protection Regulation (EU GDPR).
It is required that personal data shall be:
- Processed lawfully, fairly, and in a transparent manner in relation to individuals.
- 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.
- Adequate, relevant, and limited to what is necessary in relation to the purposes for which they are processed.
- 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.
- Kept in a form that 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 more extended 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 the implementation of the appropriate technical and organizational measures required by the DPA in order to safeguard the rights and freedoms of individuals; and
- Processed in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organizational measures.”
2. General provisions
- This policy applies to all personal data processed by the Organisation.
- The Responsible Person shall take responsibility for the Organisation’s ongoing compliance with this policy.
- This policy shall be reviewed at least annually.
- If the database falls under any of the below-listed criteria the Organisation is required to register with the Information Commissioner’s Office as an organization that processes personal data.
- the database contains data in respect of more than 10,000 data subjects.
- the database contains sensitive data.
- the database includes data about persons, and such was not provided by them, on their behalf, or with their consent.
- the database belongs to a public entity, or
- the database is used for direct mailing services.
3. Lawful, fair, and transparent processing
- To Organisation shall ensure its processing of data is lawful, fair, and transparent.
- The Organisation shall review any and all data processing on an annual basis and validate that the data processing is lawful, fair, and transparent.
- Individuals have the right to access their personal data and any such requests made to the Organisation shall be dealt with in a timely manner.
4. Lawful purposes
- All data processed by the Organisation must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests.
- The Organisation shall note the appropriate lawful basis.
- 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 the Organisation’s systems.
5. Data minimization
- The Organisation shall ensure that personal data are adequate, relevant, and limited to what is necessary in relation to the purposes for which they are processed.
6. Accuracy
- The Organisation 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.
7. Archiving/removal
- To ensure that personal data is kept for no longer than necessary, the Organisation shall review all personal data collected on an annual basis and review whether it is still deemed necessary to retain this information. This review process will occur annually.
- The review process shall consider what data should/must be retained, for how long, and why.
8. Security
- The Organisation 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 unauthorized sharing of information.
- When personal data is deleted this should be done safely such that the data is irrecoverable.
- Appropriate backup 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, unauthorized disclosure of, or access to, personal data, the Organisation shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach to
Israel – inform the Data Protection Authority (DPA) Reporting Breaches
EU – in accordance with EU data breach guidelines
Definitions
| Organization | means Haim Pharma Group Ltd, a company registered under number 516598612 |
| Privacy Law (Israel) | Protection of Privacy Law, 5741-1981 (‘the Privacy Law’) and enforced by the Privacy Protection Authority (‘PPA’) |
| GDPR (Europe) | General Data Protection Regulation is a European Union regulation on data protection and privacy in the EU and the European Economic Area. The GDPR is an important component of EU privacy law and of human rights law, |
| Responsible Person | The person assigned responsibility for data protection. |
| Register of Systems | means a register of all systems or contexts in which personal data is processed by the Organisation. |
END OF POLICY