Protecting your data and helping you with the compliance challenges set out by the new data protection regulation are our top priorities.

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We have already applied the following practice in our Operations and Technology areas:

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• Understand that data should be processed only after explicit instruction (part of DBS Partner service agreement - called “Liability Matrix”)

• The right of the client to audit DBS Partner technology activities

• Indemnity and liability issues are treated by DBS Partner with liability insurance (part of DBS Partner service agreement)

• Violation notification responsibilities, to be appointed in 2020 by Brazilian government

• Requirements to cooperate with investigations commitment as an ongoing process after the Brazilian authority is appointed

• Responsibility for deleting or returning data at the end of a contract (part of DBS Partner service agreement, under termination clause)

• Limitations on subsequent data transfer (part of DBS Partner service agreement, as well as the information confidentiality clause)

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And also....

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• Educate the company about GDPR and ensure adequate staff training (ongoing training of DBS Partner employees on Data Protection)

• Audit of data processing efforts for GDPR compliance, correction of any issues and monitoring of privacy efforts (continuous activity in DBS Partner operation)

• Serve as a point of contact for GDPR supervisory authorities (DBS Partner directors and partners are committed to authorities for clarification)

• Maintain records of all data processing activities (routine IT and Information Security activities, DBS Partner has a historical record of Inputs and Data Processing Logs)

• Communicate with data subjects regarding GDPR data requests and issues (after determination by the Brazilian federal government of the LGPD authority in 2020)

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For data processing flows, we already have:

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• To effectively protect data privacy, you first need to know what data the company has and where it comes from. This requires an effective data mapping strategy

• Starts with practice areas or departments and identifies business processes that collect, process, transfer and store personal data (DBS Partner has the mapping and responsibilities of each area involved in customer input and monthly processing of your data)

• Identifies systems and applications that store this data (DBS Partner uses defined systems and applications for each processing activity and their access is determined by the role of each employee)

• Develops data flow maps (DBS Partner data processing activities are determined by activity flow and with individual and predetermined responsibilities)

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The opposite approach consists of automation in which:

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• Starts with file systems, databases and repositories (DBS Partner has systems, databases and file repository in a secure external environment, with redundancy in another external backup environment)

• Checks for personal data based on classifications and defined data elements

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