As defined in GDPR Article 17, you have the right to be forgotten. It is the right that the Data Subject has to request the erasure of their personal information under certain circumstances. It enables the ability to have personal information an organization holds about you as an individual deleted and the discontinuance of any associated data processing.
The right to be forgotten isn’t exactly a walk in the park in a highly connected data sphere, for many organizations knowing exactly where customer data is stored is still an uncertainty, making erasure de facto, well, close to impossible. Like the DSAR, the ability to execute your Right to be Forgotten request with a high degree of confidence and accuracy is the product of having a comprehensive and maintained Data Map. Most organizations are stating the Right to be Forgotten, a.k.a. Right to Erasure, proves to be the hardest data subject right to operationalize and the most difficult GDPR obligation in practice overall as reported in the 2018 IAPP-EY Annual Privacy Governance Report (DSAR being #2).
Upon receipt of your Right to be Forgotten request form (available with the platform launch in early 2019) and the appropriate supporting documents, our Data Protection Officer will review your request and notify you of the latest date by which we aim to act upon your request. Once the request has been fully executed you will be promptly notified of the status and we will never contact you again. Blueberry, Inc. is committed to honoring your request within 30 days of receipt consistent with GDPR guidance in respect to when the right does/does not apply:
Individuals have the right to have their personal information erased if the:
The right to erasure does not apply if processing is necessary for one of the following reasons as defined in Article 23:
The method in which leads are captured, whether by site registration, web marketing, a landing page, email, referrals, a site import utility, or something else, it doesn’t matter. If personal information is being collected about individuals, then organizations need to follow the rules. In addition to having an individual’s consent, organizations must capture how the lead was sourced and maintain this in association with the individual’s information inclusive of the exact type of communications the individual agrees to receive and the date in which the organization received consent.
One thing is certain, for any organization that collects, manages, and uses personal information, GDPR will change the way in which leads are captured. However, this shouldn’t necessarily be viewed as a negative thing. After all, the leads being captured will hopefully become customers, so providing customers with a choice about how their personal information will be used is a good thing. It builds trust, instills confidence and promotes an environment of transparency.
You have a choice about whether or not you wish to receive information from us. If you do not want to receive direct marketing communications from us about new products and/or service offerings, then you may opt out of receiving these communications. We’re committed to putting you in control of your information so you’re free to change your marketing preferences (including to tell us that you don’t want to be contacted for marketing purposes) at any time.
We obtain information about you in the following ways:
We will not use your personal information for marketing purposes if you have indicated that you do not wish to be contacted by us. However, we may still need to contact you for administrative purposes or to bring awareness to a maintenance activity or a service degradation. And as always, your personal information is never shared with any third parties or affiliates for any reason whatsoever.
The personal information we collect, store and use might include:
Blueberry, Inc. and BlueberryCMS do not collect or store any personal information defined as Special Category Data under GDPR. Special Category Data is identified as being highly sensitive and therefore requires greater levels of protection from abuse. For example, information about your health, ethnicity, politics, sexual orientation or religion.
We may use your information for a number of different purposes, which may include:
We keep your information for no longer than is necessary according to the purposes it was originally collected for. The length of time in which we retain your personal information is determined by operational and legal considerations. We are legally required to hold some types of information to fulfill our statutory and regulatory obligations. We routinely review our retention periods and have automated process which remove inactive account history when it is no longer required to satisfy tax, accounting or legal obligations.
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