Data protection policy

Data protection policy

Öko-Recherche takes its responsibilities with regard to the management of the requirements of the General Data Protection Regulation (GDPR) very seriously. This policy sets out the basic principles how those responsibilities are managed.

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.”

This policy applies to all personal data we process regardless of the location where that personal data is stored (e.g. on an employee’s own device) and regardless of the data subject. All staff and subcontractors processing personal data on Öko-Recherche’s behalf must read it. A failure to comply with this policy may result in disciplinary action.

General provisions

  • This policy applies to all personal data processed by Öko-Recherche.
  • Öko-Recherche shall take responsibility for its ongoing compliance with this policy.
  • This policy shall be reviewed at least annually.

Specific provisions

All data collection and processing by Öko-Recherche must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests.

To ensure its processing of data is lawful, fair and transparent, Öko-Recherche shall introduce and maintain a data register.

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 Öko-Recherche's systems. 

Öko-Recherche will ensure that personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.

Staff who process personal data about any individual must comply with the requirements of this policy. Staff members must ensure that:

(a) all personal data is kept securely;

(b) no personal data is disclosed either verbally or in writing, accidentally or otherwise, to any unauthorised third party;

In addition to this policy, non-disclosure agreements (NDA) with companies and industry associations on business-sensitive data may be made. Staff and subcontractors collecting and/or processing business-related data will be informed about the existence and scope of such NDAs.