1. Background:

    

   Junari Ltd understands that your privacy is important to you and that you care about how your information is used and shared online. We respect and value the privacy of everyone who visits Our Site and will only collect and use information in ways that are useful to you and in a manner consistent with your rights and Our obligations under the law.

    

   This Policy applies to Our use of any and all data collected by us in relation to your use of Our Site. Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of Our Privacy Policy is deemed to occur upon your first use of Our Site. If you do not accept and agree with this Privacy Policy, you must stop using Our Site immediately.

2. Definitions and Interpretation

 

We may change this Privacy Policy as we may deem necessary from time to time, or as may be required by law. Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up to date.

 

 

If you have any questions about Our Site or this Privacy Policy, please contact Us by email at dominic.tyler@junari.com, by telephone on 01206 625 225, or by post at Junari Ltd, 1 London Road, Ipswich, England, IP1 2HA. Please ensure that your query is clear, particularly if it is a request for information about the data We hold about you (as under section 11, above).

 

Changes to Our Privacy Policy

We currently don’t make automated decisions.

 

Contacting Us

Where We use your personal data for profiling purposes, the following shall apply:

• • Clear information explaining the profiling will be provided, including its significance and the likely consequences;
  • Appropriate mathematical or statistical procedures will be used;
  • Technical and organisational measures necessary to minimise the risk of errors and to enable such errors to be easily corrected shall be implemented; and
  • All personal data processed for profiling purposes shall be secured in order to prevent discriminatory effects arising out of profiling.

In the event that We use personal data for the purposes of automated decision-making and those decisions have a legal (or similarly significant effect) on You, You have the right to challenge to such decisions under GDPR, requesting human intervention, expressing their own point of view, and obtaining an explanation of the decision from Us.

The right described above does not apply in the following circumstances:

• • The decision is necessary for the entry into, or performance of, a contract between You and Us[3] ;
  • The decision is authorised by law; or
  • You have given you explicit consent.

To enforce any of the foregoing rights or if you have any other questions about Our Site or this Privacy Policy, please contact Us using the details set out in section 14 below.

 

Automated Decision-Making and Profiling

Under the GDPR, you have:

• • the right to request access to, deletion of or correction of, your personal data held by Us;
  • the right to complain to a supervisory authority;
  • be informed of what data processing is taking place;
  • the right to restrict processing;
  • the right to data portability;
  • object to the processing of your personal data;
  • rights with respect to automated decision-making and profiling (see section 14 below).

You have the legal right to ask for a copy of any of your personal data held by Us (where such data is held). Please contact Us for more details at dominic.tyler@junari.com, or using the contact details below in section 14.

 

 

Summary of Your Rights under GDPR

You may access certain areas of Our Site without providing any data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.

You may restrict your internet browser’s use of Cookies. For more information, see the relevant section of https://www.junaricrmplus.com/junaricrm-client-terms-conditions.html/

You may withdraw your consent for Us to use your personal data as set out in section in 5 at any time by contacting Us using the details set out in section 14, and We will delete Your data from Our systems.  However, you acknowledge this may limit Our ability to provide the best possible products and services to you.

 

How Can You Access Your Data?

When you submit information via Our Site, you may be given options to restrict Our use of your data. We aim to give you strong controls on Our use of your data (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and/or by contacting us using the details provided at section 14 of this privacy policy.

You may also wish to sign up to one or more of the preference services operating in the United Kingdom: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you from receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receive.

 

Your Right to Withhold Information and Your Right to Withdraw Information After You Have Given it

We may, from time to time, expand or reduce Our business and this may involve the sale and/or the transfer of control of all or part of Our business. Data provided by Users will, where it is relevant to any part of Our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use the data for the purposes for which it was originally collected by Us.

In the event that any of your data is to be transferred in such a manner, you will be contacted in advance and informed of the changes.

 

How Can You Control Your Data?

We may share your data with other companies in Our group within EEA and outside. This includes our subsidiaries and/or our holding company and its subsidiaries.[2] 

We may contract with third parties to supply [products and] services to you on Our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law.

We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales and other information. All such data will be anonymised and will not include any personally identifying information. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, advertisers and our marketing agency. Data will only be shared and used within the bounds of the law.

In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal information, for example, where We are involved in legal proceedings, where We are complying with the requirements of legislation, a court order, or a governmental authority. We do not require any further consent from you in order to share your data in such circumstances and will comply as required with any legally binding request that is made of Us.

 

 

What Happens If Our Business Changes Hands?

 

Do We Share Your Data? only keep your data for as long as We need to in order to use it as described above in section 5, and/or for as long as We have your permission to keep it.  In any event, will conduct an annual review to ascertain whether we need to keep your data. Your data will be deleted if we no longer need it in accordance with the terms of our Data Retention Policy. Our Data Retention Policies are:

 

 

• • When it is necessary for business purposes and development your data will be transferred outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland and Liechtenstein). You are deemed to accept and agree to this by using Our Site and submitting information to Us. If we do store or transfer data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the EEA and under the GDPR. Such steps may include, but not be limited to, the use of legally binding contractual terms between Us and any third parties We engage and the use of the EU-approved Model Contractual Contract Clauses. If We intend at any time to transfer any of your data outside the EEA, We will always obtain your consent beforehand and we have put in place safeguards to protect your data.[1] 
  • Data security is of great importance to Us, and to protect your data We have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through Our Site.
  • Notwithstanding the security measures that We take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to Us data via the internet.

 

 

 

How and Where Do We Store Your Data? GDPR, we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following basis applies:

• • you have given consent to the processing of your personal data for one or more specific purposes;
  • processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract;
  • processing is necessary for compliance with a legal obligation to which we are subject;
  • processing is necessary to protect the vital interests of you or of another natural person;
  • 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; and/or
  • processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.

 

some cases, the collection of data may be a statutory or contractual requirement, and we will be limited in the products and services We can provide you without your consent for Us to be able to use such data. your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email AND/OR telephone AND/OR text message AND/OR post with information, news and offers on Our products AND/OR services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, as amended in 2004, 2011 and 2015.

 

 

 

 

 

 

may also take the opportunity to:

• • Contact you about products that are closely related to those you already hold with us
  • Provide additional assistance or tips about these products or services
  • Notify you of important functionality changes to our websites
  • Conducting surveys and market research about our customers, their interests, the effectiveness of our marketing campaigns, and customer satisfaction (unless we need consent to undertake such surveys, in which case we will only do this with your permission)

use your data to provide the best possible product, services and support to you. This includes:

• • Assess and provide the products or services that you have requested
  • Providing you with the software solutions and apps for which you have registered, and any other services or products that you have requested
  • Verifying your identity
  • Sending you necessary communications
  • Develop new products and services
  • Undertake statistical analysis
  • Providing customer service or support
  • Diagnosing problems in our apps and websites
  • Investigating and responding to any comments or complaints that you may send us
  • In connection with legal claims, compliance, regulatory and investigative purposes as necessary (including disclosure of information in connection with legal process or litigation)

personal data is stored securely in accordance with the EU General Data Protection Regulation (Regulation (EU) 2016/679) (GDPR). For more details on security, see section 6, below.

 

How Do We Use Your Data? categories of data subjects may include representatives and end-users, including employees, contractors, agency and temporary personnel, of the Customer and its affiliates, and the Customer’s or its affiliates’ clients, prospective clients, suppliers and other individuals about whom personal data is submitted to Company by or at the direction of the Customer as part of the products or services.

Some data will be collected automatically by Our Site (for further details, please see our T&Cs at https://www.junaricrmplus.com/junaricrm-client-terms-conditions.html, other data will only be collected if you voluntarily submit it and consent to us using it for the purposes set out in section 5, for example, when signing up for an Account.

 

 

 

types of personal data processed may include full name, email addresses, postal addresses, office/institution postal address, social media handles, telephone, mobile phone numbers, business cards and job titles, work section, username and passwords for accessing and using the products and services, purchase/license/ inquiry history; goods, services; usage data and statistics; connection data; locale data; other unique identifiers such as IP addresses or device IDs; marketing and advertising responses and preferences; results data from the products and services which may include other third-party data and other types of personal data identified in the GDPR, and/or documents, images or other content containing Personal Data submitted by or at the direction of Customer as part of the products and services.

                This Privacy Policy applies only to your use of Our Site. It does not extend to any websites that are linked to from Our Site (whether We provide those links or whether they are shared by other users). We have no control over how your data is collected, stored or used by other websites and We advise you to check the privacy policies of any such websites before providing any data to them.

 

What Data Do We Collect?

Our Site, www.junari.com, is owned and operated by Junari, a limited company registered in England under Company Registration number 5683385, whose registered address is 1 London Road, Ipswich, England, IP1 2HA. Our VAT number is GB 932497012.

Our company does not have an appointed Data Protection Officer, for any information contact Dominic Tyler, Junari’s Managing Director who can be contacted at dominic.tyler@junari.com

 

Scope – What Does This Policy Cover?

In this Policy the following terms shall have the following meanings: 

 

`                                 Data Breach Policy           Approval and Review Details Approval Authority Director Information Controller Officer Dominic Tyler Next Review Date 09.09.2020 Version 1.3 Updated on 16/09/2019                 CONTENTS   1.     Introduction   3 2.     Definitions  3 3.     Detection of personal data breaches  3 4.     Responding to personal data breaches  4 5.     Notification to the supervisory authority  4 6.     Notification to the data controller  5 7.     Notification to data subjects  6 8.     Other notifications  7 9.     Investigation and risk assessment  7 10.   Approval and review details  8 11.   Response plan and template   8           Introduction This policy sets out the policies and procedures of Junari Ltd (the "company") with respect to [detection of personal data breaches, responding to personal data breaches and notification of personal data breaches to supervisory authorities, data controllers and data subjects].   When dealing with personal data breaches, the company and all company personnel must focus on protecting individuals and their personal data, as well as protecting the interests of the company.     Definitions In this policy:   "appointed person" means the individual primarily responsible for dealing with personal data breaches affecting the company, being Dominic Tyler who can be contacted at dominic.tyler@junari.com;   “data controller" means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data;   “data processor" means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;   “data subject" means an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;   "personal data” means any information relating to a data subject;   "personal data breach" means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed by the company (including any temporary or permanent loss of control of, or inability to access, personal data); and    "supervisory authority" means [the Information Commissioner's Office of the United Kingdom].     Detection of personal data breaches   Junari Ltd is committed to regularly review the technical and organisational measures it uses to detect incidents which may result in a personal data breach. Such reviews shall be carried out annually.                   Responding to personal data breaches All personnel of the company must notify the appointed person immediately if they become aware of any actual or possible personal data breach.   The appointed person is primarily responsible for investigating possible and actual personal data breaches and for determining whether any notification obligations apply. Where notification obligations apply, the appointed person is responsible for notifying the relevant third parties in accordance with this policy.   All personnel of the company must cooperate with the appointed person in relation to the investigation and notification of personal data breaches.   The appointed person must determine whether the company is acting as a data controller and/or a data processor with respect to each category of personal data that is subject to a personal data breach.   The steps to be taken by the appointed person when responding to a personal data breach may include:   ensuring that the personal data breach is contained as soon as possible;   assessing the level of risk to data subjects as soon as possible;   gathering and collating information from all relevant sources;   considering relevant data protection impact assessments;   informing all interested persons within the company of the personal data breach and the investigation;   assessing the level of risk to the company; and   notifying supervisory authorities, data controllers, data subjects and others of the breach in accordance with this policy.   The appointed person shall keep a full record of the response of the company to a personal data breach, including the facts relating to the personal data breach, its effects and the remedial action is taken. This record shall form part of the personal data breach register of the company.     Notification to the supervisory authority This section applies to personal data breaches affecting personal data with respect to which the company is acting as a data controller.   The company must notify the supervisory authority of any personal data breach to which this section 5 applies without undue delay and, where feasible, not later than 72 hours after the company becomes aware of the breach, save as set out in the next subsection.   The company will not notify the supervisory authority of a personal data breach where it is unlikely to result in a risk to the rights and freedoms of natural persons. The appointed person shall be responsible for determining whether this subsection applies, and the appointed person must create a record of any decision not to notify the supervisory authority. This record should include the appointed person's reasons for believing that the breach is unlikely to result in a risk to the rights and freedoms of natural person. This record shall be stored as part of the personal data breach register of the company. Personal data breach notifications to the supervisory authority must be made by the appointed person using the form (Notification of personal data breach to ICO). The completed form must be sent to the supervisory authority by secure and confidential means. The appointed person must keep a record of all notifications, and all other communications with the supervisory authority relating to the breach, as part of the personal data breach register of the company.   To the extent that the company is not able to provide to the supervisory authority all the information specified in the form (Notification of personal data breach to ICO). at the time of the initial notification to the supervisory authority, the company must make all reasonable efforts to ascertain the missing information. That information must be provided to the supervisory authority, by the appointed person, as and when it becomes available. The appointed person must create a record of the reasons for any delayed notification under this subsection. This record shall be stored as part of the personal data breach register of the company.   The company must keep the supervisory authority informed of changes in the facts ascertained by the company which affect any notification made under section 5.   Notification of personal data breach to ICO:       Notification to the data controller This section applies to personal data breaches affecting personal data with respect to which the company is acting as a data processor.   The company must notify the affected data controller(s) of any personal data breach to which this section 6 applies without undue delay and, where feasible, not later than 72 hours after the company becomes aware of the breach. In addition, the company must comply with the provisions of the contract(s) with the affected data controller(s) relating to such notifications.   Personal data breach notifications to the affected data controller(s) must be made by the appointed person using the predetermined method or form between the companies. The completed form must be sent to the affected data controller(s) by secure and confidential means. The appointed person must keep a record of all notifications, and all other communications with the affected data controller(s) relating to the breach, as part of the personal data breach register of the company.   To the extent that the company is not able to provide to the affected data controller(s) all the information specified at the time of the initial notification to the affected data controller(s), the company must make all reasonable efforts to ascertain the missing information. That information must be provided to the affected data controller(s), by the appointed person, as and when it becomes available.                 Notification to data subjects This section applies to personal data breaches affecting personal data with respect to which the company is acting as a data controller.   Notifications to data subject under this section should, where appropriate, be made in consultation with the supervisory authority and in accordance with any guidance given by the supervisory authority with respect to such notifications.   The company must notify the affected data subjects of any personal data breach to which this section applies if the personal data breach is likely to result in a high risk to the rights and freedoms of natural persons.   Personal data breach notifications to the affected data subjects must be made by the appointed person in clear and plain language using the form (Notification of personal data breach to the data subject). The completed form must be sent to the affected data subjects by [appropriate means]. The appointed person must keep a record of all notifications, and all other communications with the affected data subjects relating to the breach, as part of [the personal data breach register of the company].   The company has no obligation to notify the affected data subject of a personal data breach if:   the company has implemented appropriate technical and organisational protection measures (in particular those that render the personal data unintelligible to any person who is not authorised to access it, such as encryption), and those measures have been applied to the personal data affected by the personal data breach;   the company has taken subsequent measures which ensure that high risk to the rights and freedoms of data subjects is no longer likely to materialise;   it would involve disproportionate effort (in which case, there shall instead be a public communication or similar measure whereby the data subjects are informed in an equally effective manner),   providing that the appointed person shall be responsible for determining whether this subsection applies, and the appointed person must create a record of any decision not to notify the affected data subjects. This record should include the appointed person's reasons for believing that the breach does not need to be notified to the affected data subjects. This record shall be stored as part of the personal data breach register of the company.   If the company is not required by this section to notify affected data subjects of a personal data breach, the company may nonetheless do so where such notification is in the interests of the company and/or the affected data subjects.   Notification of personal data breach to the data subject:                 Other notifications Without affecting the notification obligations set out elsewhere in this policy, the appointed person should also consider whether to notify any other third parties of a personal data breach. Notifications may be required under law or contract. Relevant third parties may include:   the police;   other law enforcement agencies;   insurance companies if applicable;   professional bodies if applicable;   regulatory authorities if applicable;   financial institutions if applicable;   trade unions or other employee representatives if applicable.   Without affecting the notification obligations set out elsewhere in this policy, the appointed person should also consider whether to notify any other third parties of a personal data breach. Notifications may be required under law or contract. Relevant third parties may include: The Information Controller Officer consultation with relevant colleagues will establish whether the Information Commissioner’s Office will need to be notified of the breach and if so, notify them within 72 hours of becoming aware of the breach, where feasible.     Investigation and risk assessment An investigation will be undertaken by the company immediately and wherever possible, within 24 hours of the breach being discovered/reported.   The company will investigate the breach and assess the risks associated with it, for example, the potential adverse consequences for individuals, how serious or substantial those are and how likely they are to occur.   The investigation will need to consider the following:   the type of data involved   its sensitivity;   the protections are in place (e.g. encryptions);   what has happened to the data (e.g. has it been lost or stolen);   whether the data could be put to any illegal or inappropriate use;   the data subject(s) affected by the breach, number of individuals involved and the potential effects on those data subject(s);   whether there are wider consequences to the breach.   Approval and review details   This policy must be reviewed and updated annually. The following matters must be considered as pan of each review of this policy: changes to the legal and regulatory environment;   changes to any codes of conduct to which the company subscribes;   developments in industry best practice;   any new data collected by the company;   any new data processing activities are undertaken by the company, and   any security incidents affecting the company.   Response plan and template Response plan template   Data breach team   Data breach team lead:   Other members of data breach team:   Background   Name and department of person notifying actual or suspected breach:   Date of actual or suspected breach:   Date of discovery of actual or suspected breach:   Date of internal notification of actual or suspected breach:   Preliminary assessment   Summary of the facts relating to the actual or suspected breach, including the types of personal data involved:   Categories and the approximate number of affected data subjects:   Categories and the approximate number of affected records:   How sensitive is the personal data?   Cause of the actual or suspected breach:   Any other relevant information or comments:   Containment and recovery   Is the actual or suspected breach ongoing?   What steps can be taken to contain the breach, i.e. to stop or minimise further loss, destruction or unauthorised disclosure?   What steps can be taken to recover any lost personal data?   Does the breach need to be reported to the police, for example, if there is evidence of theft?   Does any professional regulator or trade body need to be notified of the breach?   Does the breach need to be reported to any relevant insurers, e.g. professional indemnity?   Detailed assessment   What types of personal data are involved, and does the breach involve any special categories of personal data or personal data relating to criminal convictions and offences?   Who is affected by the breach?   What are the likely consequences of the breach for affected data subjects?   Where personal data has been lost or stolen, are any protections in place such as encryption?   What has happened to the personal data?   What uses could the third party make of the personal data?   Are there any other personal data breaches?   Has the breach been recorded in the data breach register?   Any other relevant information or comments:   Notifying the ICO   What is the type of breach?   What is the nature of the personal data affected?   What is the potential harm to data subjects?   What is the sensitivity of the personal data affected?   What is the volume of personal data affected?   How easy is it to identify data subjects from the personal data?   What is the number of affected data subjects?   Any other relevant information or comments:   Taking the above into account, is there a legal obligation to notify the ICO?   Notifying affected data subjects   Is there a legal or contractual obligation to notify affected data subjects?   If there is no legal or contractual obligation, should affected data subjects be notified anyway? Consider whether it will help them to know or whether there is a danger of over-notifying.   What is the best way to notify the affected data subjects?   Do any data subjects, or categories of data subjects, need to be treated with care because of their special characteristics?   What additional information should be provided to data subjects about what they can do to limit the damage?   How should affected data subjects contact the Company for further information or advice and how will we manage such responses?   How will we keep a record of who has been notified?   Any other relevant information or comments:   Is there any legal or contractual requirement to notify any other parties?   Response   What security measures were in place when the breach occurred?   What further measures have been, or are to be, put in place to address the breach and mitigate its possible adverse effects? Please also outline the timetable for any measures that have not yet been taken.   What further technical or organisational measures are to be put in place to prevent the breach from happening again?   Does further staff training on data protection awareness need to be conducted?   Is it necessary to conduct a privacy risk assessment?   Any other comments:   Approval of the response plan   Name:   Job title:   Date:   Signature:           Examples of personal data breaches and who to notify The following non-exhaustive examples will assist the data breach team in determining whether they need to notify in different personal data breach scenarios. These examples may also help to distinguish between risk and high risk to the rights and freedoms of data subjects.   Example Notify the ICO? Notify data subjects? Notes The Company stored a backup of an archive of personal data encrypted on a CD and the CD is stolen during a burglary No No If the personal data are encrypted with a state-of-the-art algorithm, backups of the data exist, and the unique key is not compromised, this may not be a reportable breach. However, if it is later compromised, notification is required Personal data are exfiltrated from a secure website managed by the Company during a cyber-attack Yes, if there are potential consequences to individuals Yes, depending on the nature of the personal data affected and if the severity of the potential consequences to data subjects is high If the risk is not high, the Company can still notify data subjects, depending on the circumstances of the case A brief power outage lasting several minutes means that clients are unable to call the Company and access their records No No This is not a notifiable personal data breach, but it is still a recordable incident The Company suffers a ransomware attack which results in all personal data being encrypted, no backups are available, and the personal data cannot be restored On investigation, it becomes clear that the ransomware’s only functionality was to encrypt the personal data, and that there was no other malware present in the system Yes, if there are potential consequences to individuals as this is a loss of availability Yes, depending on the nature of the personal data affected and the possible effect of the lack of availability of the personal data, as well as other likely consequences If there was a backup available and personal data could be restored in good time, this would not need to be reported to the ICO or to data subjects as there would have been no permanent loss of availability or confidentiality An employee reports that they have received a monthly payslip for another employee and a short investigation reveals that it is a systemic flaw and other employees may be affected Yes Only if there is a high risk If, after further investigation, it is identified that more employees are affected, an update to the ICO must be made and the Company must take the additional step of notifying those other data subjects if there is high risk to them The Company’s website suffers a cyber-attack and customer’s login usernames, passwords and purchase history are published online by the attacker Yes Yes, as could lead to high risk The Company should act, e.g. by forcing password resets of the affected accounts, as well as other steps to mitigate the risk Client’s personal data are mistakenly sent to the wrong mailing list Yes Yes, depending on the scope and type of personal data involved and the severity of possible consequences   A direct marketing e-mail is sent to recipients in the affected fields, thereby enabling each recipient to see the e-mail address of other recipients Yes, notifying may be obligatory if many individuals are affected, if sensitive personal data are revealed or if other factors present high risks, e.g. the e-mail contains passwords Yes, depending on the scope and type of personal data involved and the severity of possible consequences Notification may not be necessary if no sensitive personal data is revealed and if only a minor number of e-mail addresses are revealed

 

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