General Data Protection Policy

a) Right of confirmation

Every data subject shall have the right, granted by the European Directive and the Regulation, to obtain confirmation from the controller as to whether personal data concerning him or her are being processed. If a data subject wishes to exercise this right, he or she may, at any time, contact any employee of the controller.

b) Right of information

Any person concerned by the processing of personal data has the right, granted by the European Directive and Regulation, to obtain from the controller, at any time and free of charge, information about the personal data stored about him or her and a copy of that information. Furthermore, the European Directive and Regulation has granted the data subject access to the following information:

the processing purposes

the categories of personal data that are processed

the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular in the case of recipients in third countries or international organisations

if possible, the planned duration for which the personal data will be stored or, if this is not possible, the criteria for determining this duration

the existence of a right to obtain the rectification or erasure of personal data concerning them or to obtain the restriction of processing by the controller or a right to object to such processing

the existence of a right of appeal to a supervisory authority

if the personal data are not collected from the data subject: All available information on the origin of the data

the existence of automated decision-making, including profiling, pursuant to Article 22(1) and (4) of the GDPR and, at least in these cases, meaningful information about the logic involved and the scope and intended effects of such processing for the data subject

Furthermore, the data subject has the right to be informed whether personal data have been transferred to a third country or to an international organisation. If this is the case, the data subject also has the right to obtain information on the appropriate safeguards in connection with the transfer.

If a data subject wishes to exercise this right of access, he or she may contact an employee of the controller at any time.

c) Right of correction

Any person affected by the processing of personal data shall have the right granted by the European Directive and Regulation to obtain the rectification without delay of inaccurate personal data concerning him or her. Furthermore, the data subject has the right to request the completion of incomplete personal data, including by means of a supplementary declaration, taking into account the purposes of the processing. If a data subject wishes to exercise this right of rectification, he or she may, at any time, contact any employee of the controller.

d) Right of erasure (right to be forgotten)

Any person concerned by the processing of personal data shall have the right, granted by the European Parliament and the Council, to obtain from the controller the erasure without delay of personal data concerning him or her, where one of the following reasons applies and insofar as the processing is not necessary:

The personal data were collected or otherwise processed for purposes for which they are no longer necessary.

The data subject revokes the consent on which the processing was based pursuant to Article 6(1a) of the GDPR or Article 9(2a) of the GDPR and there is no other legal basis for the processing.

The data subject objects to the processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) of the GDPR.

The personal data have been processed unlawfully

The deletion of the personal data is necessary for compliance with a legal obligation under Union or Member State law to which the controller is subject.

The personal data was collected in relation to information society services offered pursuant to Art. 8(1) of the GDPR.

If one of the aforementioned reasons applies, and a data subject wishes to arrange for the deletion of personal data stored by DOCPA, he or she may, at any time, contact any employee of the controller. The employee of DOCPA will arrange for the deletion request to be complied with immediately.

If the personal data have been made public by DOCPA and our enterprise as the controller is obliged to delete the personal data pursuant to Article 17 (1) of the Data Protection Regulation, DOCPA shall take reasonable measures, including technical measures, to ensure that other data controllers, who process the published personal data, are informed of the fact that the data subject has requested from those other data controllers the deletion of all links to the personal data or of copies or replications of the personal data, unless the processing is necessary, taking into account the available technology and the cost of implementation. The employee of DOCPA will arrange the necessary in individual cases.

e) Right to restrict processing

Any person concerned by the processing of personal data has the right, granted by the European Directive and the Regulation, to obtain from the controller the restriction of processing where one of the following conditions is met:

The accuracy of the personal data is contested by the data subject for a period enabling the controller to verify the accuracy of the personal data.

The processing is unlawful, the data subject objects to the erasure of the personal data and requests instead the restriction of the use of the personal data.

The controller no longer needs the personal data for the purposes of processing, but the data subject needs it for the establishment, exercise or defense of legal claims.

The data subject has objected to the processing pursuant to Article 21(1) of the GDPR and it is not yet clear whether the legitimate grounds of the controller override those of the data subject.

If one of the aforementioned conditions is met, and a data subject wishes to request the restriction of personal data stored by DOCPA, he or she may, at any time, contact any employee of the controller. The employee of DOCPA will arrange the restriction of the processing.

f) Right of data portability

Any person concerned by the processing of personal data shall have the right, granted by the European Directive and the Regulation, to receive the personal data concerning him or her, which have been provided by the data subject to a controller, in a structured, commonly used and machine-readable format. The data subject shall also have the right to transmit such data to another controller without hindrance from the controller to whom the personal data have been provided, provided that the processing is based on consent pursuant to Article 6(1a) of the GDPR or Article 9(2a) of the GDPR or on a contract pursuant to Article 6(1b) of the GDPR and the processing is carried out by automated means, unless the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

Furthermore, when exercising the right to data portability pursuant to Article 20(1) of the GDPR, the data subject shall have the right to obtain the direct transfer of personal data from one controller to another controller where technically feasible and provided that this does not adversely affect the rights and freedoms of other persons. In order to assert the right to data portability, the data subject may at any time contact any employee of DOCPA.

g) Right of withdrawal

Any person affected by the processing of personal data shall have the right granted by the European Directive and Regulation to object at any time, on grounds relating to his or her particular situation, to the processing of personal data concerning him or her which is carried out on the basis of Article 6(1e-f) of the GDPR. This also applies to profiling based on these provisions.

DOCPA shall no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the assertion, exercise or defense of legal claims.

If DOCPA processes personal data for the purpose of direct marketing, the data subject shall have the right to object at any time to processing of personal data processed for such marketing. This also applies to profiling insofar as it is related to such direct marketing. If the data subject objects to DOCPA to the processing for direct marketing purposes, DOCPA will no longer process the personal data for these purposes.

In addition, the data subject has the right, on grounds relating to his or her particular situation, to object to processing of personal data concerning him or her which is carried out by DOCPA for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the Data Protection Regulation, unless such processing is necessary for the performance of a task carried out in the public interest.

In order to exercise the right to object, the data subject may directly contact any employee of DOCPA or another employee. The data subject is also free, in connection with the use of information society services, notwithstanding Directive 2002/58/EC, to exercise his or her right to object by means of automated procedures using technical specifications.

h) automated decisions including profiling

Any person concerned by the processing of personal data shall have the right, granted by the European Directive and the Regulation, not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her, provided that the decision (1) is not necessary for entering into, or the performance of, a contract between the data subject and the controller, or (2) is authorised by Union or Member State law to which the controller is subject and that such law lays down appropriate measures to safeguard the data subject's rights and freedoms and legitimate interests, or (3) is made with the data subject's explicit consent.

If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and the data controller, or (2) it is made with the data subject's explicit consent, DOCPA shall implement suitable measures to safeguard the data subject's rights and freedoms and legitimate interests, which include at least the right to obtain the data subject's involvement on the part of the controller, to express his or her point of view and to contest the decision.

If the data subject wishes to exercise the rights concerning automated decisions, he or she may, at any time, contact any employee of the controller.

i) Right to revoke consent under data protection law

Every person affected by the processing of personal data has the right granted by the European Directive and Regulation to withdraw consent to the processing of personal data at any time. If the data subject wishes to exercise the right to withdraw consent, he or she may, at any time, contact any employee of the controller.