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Personal Data Processing and Protection Policy
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Personal Data Processing and Protection Policy
GENERAL PROVISIONS
In order to comply with the legislation of the Russian Federation regulating relations related to the processing and security of personal data, as well as to maintain the business reputation of the Limited Liability Company “Octagon” (hereinafter – LLC “Octagon”) considers its tasks to comply with the principles of legality, fairness and confidentiality in the processing of personal data, as well as ensuring the security of their processes processing.
This Policy regarding the processing and protection of personal data in Oktagon LLC (hereinafter referred to as the Policy):
Discloses the main categories of personal data processed by Oktagon LLC, the purposes, methods and principles of personal data processing, the rights and obligations of Oktagon LLC in the processing of personal data, the rights of personal data subjects.
It is a publicly available document declaring the conceptual foundations of the activities of Oktagon LLC in the processing of personal data.
Terms and definitions used in the Policy:
Biometric personal data is information that characterizes the physiological and biological characteristics of a person, on the basis of which it is possible to establish his identity and which is used by the operator to establish the identity of the subject of personal data.
Blocking of personal data is a temporary termination of the processing of personal data (except in cases where processing is necessary to clarify personal data).
Access to information (access) — familiarization with information, its processing, in particular, copying, modification or destruction of information.
The Personal Data Information System (hereinafter referred to as ISPDn) is a set of personal data contained in databases and information technologies and technical means that ensure their processing.
Unauthorized access (NSD) is access to information stored on various types of media (paper, magnetic, optical, etc.) in computer databases, file repositories, archives, secret parts, etc. of various organizations by changing (increasing, falsifying) their access rights.
A data carrier is any material object or medium used for storing or transmitting information.
Personal data (hereinafter – PD) — any information relating directly or indirectly to a specific or identifiable individual (subject of personal data).
Operator — a state body, municipal body, legal entity or individual, independently or jointly with other persons organizing and (or) processing personal data, as well as determining the purposes of processing personal data, the composition of personal data to be processed, actions (operations) performed with personal data. The operator is Oktagon LLC.
Personal data processing — any action (operation) or a set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
Provision of personal data — actions aimed at disclosure of personal data to a certain person or a certain circle of persons.
Dissemination of personal data — actions aimed at disclosure of personal data to an indefinite circle of persons.
Special categories of personal data — categories of personal data concerning race, nationality, political views, religious or philosophical beliefs, health status, intimate life.
The subject of personal data (subject) is an individual who is directly or indirectly identified or determined using personal data.
Cross—border transfer of personal data is the transfer of personal data to the territory of a foreign state to an authority of a foreign state, a foreign individual or a foreign legal entity.
Destruction of personal data — actions as a result of which it becomes impossible to restore the content of personal data in the personal data information system and (or) as a result of which the material carriers of personal data are destroyed.
Basic rights of Personal data subjects:
The subject of personal data has the right to receive information about the processing of his personal data in Oktagon LLC;
The subject of personal data has the right to demand from Oktagon LLC, which processes them, clarification of these personal data, their blocking or destruction if they are incomplete, outdated, inaccurate, illegally obtained or cannot be recognized as necessary for the stated purpose of processing, as well as to take measures provided by law to protect their rights;
The right of the Subject of personal data to access his personal data may be restricted in accordance with federal laws;
In order to exercise their rights and protect their legitimate interests, the Subject of personal data has the right to contact Oktagon LLC. The latter considers any appeals and complaints from personal data subjects, thoroughly investigates the facts of violations and takes all necessary measures to eliminate them immediately, punish the perpetrators and settle disputes and conflict situations in a pre-trial manner;
The subject of personal data has the right to appeal against the actions or inaction of Oktagon LLC by contacting the authorized body for the protection of the rights of personal data subjects (the territorial body of the Federal Service for Supervision in the Field of Communications, Information Technology and Mass Communications);
The subject of personal data has the right to protect his rights and legitimate interests, including compensation for damages and/or compensation for moral damage in court.
Main responsibilities of Oktagon LLC :
Comply with the requirements of the legislation of the Russian Federation in the field of processing and protection of personal data;
When collecting personal data, provide the subject of personal data, at his request, with information concerning the processing of personal data;
If the provision of personal data is mandatory in accordance with federal law, employees of Oktagon LLC are required to explain to the subject of personal data the legal consequences of refusing to provide his personal data;
When collecting personal data, including through the Internet information and telecommunications network, to ensure the recording, systematization, accumulation, storage, clarification (updating, modification), extraction of personal data of citizens of the Russian Federation using databases located on the territory of the Russian Federation;
Publish or otherwise provide unrestricted access to an up-to-date document defining its policy regarding the processing of personal data, to information about the implemented requirements for the protection of personal data (this Policy);
Take the necessary legal, organizational and technical measures or ensure their adoption to protect personal data from unauthorized or accidental access to them;
Inform the personal data subject or his representative about the availability of personal data related to the relevant personal data subject, as well as provide an opportunity to get acquainted with these personal data when contacting the personal data subject or his representative;
To clarify the personal data of Subjects, block or destroy them if they are incomplete, outdated, inaccurate, illegally obtained or cannot be recognized as necessary for the stated purpose of processing;
Terminate the processing of personal data in case the subject of personal data withdraws consent to the processing of his personal data. Oktagon LLC has the right to continue processing personal data without the consent of the personal data subject if there are grounds specified in paragraphs 2-11 of Part 1 of Article 6, Part 2 of Article 10 and Part 2 of Article 11 of Federal Law No. 152—FZ of 27.07.2006 “On Personal Data”.
PURPOSES OF PERSONAL DATA COLLECTION
Oktagon LLC processes the following categories of personal data subjects (hereinafter referred to as Subjects):
Personal data of employees.
Personal data of employees’ relatives.
Personal data of former employees.
Personal data of candidates for vacant positions.
Personal data of trainees;
Personal data of students;
Personal data of guests and their legal representatives.
Personal data of counterparties;
Personal data of representatives/employees of counterparties (legal entities).
Oktagon LLC processes personal data of employees exclusively for the following purposes:
Compliance with the requirements of the legislation of the Russian Federation;
Implementation of labor relations;
Conclusion and fulfillment of obligations under labor contracts;
Accounting, tax and personnel accounting;
Organization of access control;
Conducting mandatory preliminary and periodic medical examinations (examinations) of employees;
Organization and conduct of training and advanced training;
Crediting employees with wages, advances, reimbursement of travel, representative, business expenses and social benefits to an employee’s account opened in any bank of the Russian Federation.
Crediting to each employee the amount of wages and other types of payment due to him, an advance of travel and business expenses, copyright and other remuneration under civil law contracts to his account in rubles opened in any bank of the Russian Federation.
Increasing customer loyalty to the company.
Oktagon LLC processes personal data of relatives of employees solely for the purpose of personnel records management.
Oktagon LLC processes personal data of former employees solely for accounting purposes.
Oktagon LLC processes the personal data of trainees solely for the purpose of organizing and conducting practice.
Oktagon LLC processes personal data of students solely for the purpose of concluding and fulfilling obligations under civil contracts.
Oktagon LLC processes personal data of candidates for vacant positions exclusively for the following purposes:
Making a decision on employment;
Formation of a personnel reserve.
Oktagon LLC processes personal data of guests and their legal representatives exclusively for the following purposes:
Provision of temporary accommodation (short-term rental) services in the premises, at the address of Oktagon LLC ;
Registration of a citizen of the Russian Federation at the place of stay and removal of a citizen of the Russian Federation from the registration register at the place of stay;
Implementation of migration registration of foreign citizens and stateless persons in the Russian Federation;
Compliance with the requirements of the legislation of the Russian Federation.
Oktagon LLC processes the personal data of counterparties exclusively for the following purposes:
Conclusion and fulfillment of obligations under contracts with counterparties
Accounting and tax accounting.
Oktagon LLC processes personal data of representatives/employees of counterparties (legal entities) solely for the purpose of concluding and fulfilling obligations under contracts with counterparties.
LEGAL GROUNDS FOR PROCESSING PERSONAL DATA
The legal basis for the processing of personal data is a set of legal acts, pursuant to which and in accordance with which Oktagon LLC processes personal data.
The processing of personal data in Oktagon LLC is carried out in accordance with the following legal grounds:
The Constitution of the Russian Federation of 25.12.1993;
Labor Code of the Russian Federation No. 197-FZ dated 30.12.2001;
Civil Code of the Russian Federation No. 51-FZ dated 30.11.1994;
Criminal Code of the Russian Federation No. 63-FZ of 13.06.1996;
The Code of the Russian Federation on Administrative Offences of 30.12.2001 No. 195-FZ;
The Tax Code of the Russian Federation Part one of 31.07.1998 No. 146-FZ and Part Two of 05.08.2000 No. 117-FZ (with amendments and additions);
Federal Law No. 59-FZ of 02.05.2006 “On the procedure for considering appeals of citizens of the Russian Federation”;
Federal Law No. 109-FZ of 18.07.2006 “On Migration Registration of Foreign Citizens and Stateless Persons in the Russian Federation”;
Federal Law No. 273-FZ of 29.12.2012 “On Education in the Russian Federation”;
Law of the Russian Federation of 25.06.1993 No. 5242-I “On the right of citizens of the Russian Federation to freedom of Movement, Choice of Place of Stay and Residence within the Russian Federation”;
Resolution of the Government of the Russian Federation No. 9 dated 15.01.2007 “On the Procedure for migration Registration of foreign Citizens and Stateless persons in the Russian Federation”;
Resolution of the Government of the Russian Federation of 17.07.1995 No. 713 “On approval of the Rules for Registration and Removal of Citizens of the Russian Federation from the registration register at the place of stay and at the place of Residence within the Russian Federation and the list of persons responsible for receiving and Transferring to the registration authorities documents for registration and removal from the registration register of citizens of the Russian Federation at the place of stay and at the place of residence within the Russian Federation”;
Decree of the Government of the Russian Federation No. 310 dated 10.05.2010 “On Approval of the Rules for Transmitting Information about the Arrival at the place of Stay and Departure from the place of Stay of Foreign Citizens and Stateless Persons using Means of Communication included in the telecommunication network”;
Order of the Ministry of Health and Social Development of the Russian Federation No. 302n dated 12.04.2011 “On Approval of Lists of harmful and (or) Hazardous Production Factors and Works, during which Mandatory Preliminary and periodic Medical examinations (examinations) are carried out, and the procedure for Mandatory preliminary and periodic Medical examinations (examinations) of workers Engaged in Heavy Work and Work with Harmful and (or) dangerous working conditions”;
Resolution of the Board of the Pension Fund of the Russian Federation No. 192p dated 31.07.2006 “On the forms of individual (personalized) accounting documents in the mandatory pension insurance system and instructions for completing them”;
Order of the Ministry of Internal Affairs of the Russian Federation No. 881 dated 11/23/2017 “On Approval of the Administrative Regulations of the Ministry of Internal Affairs of the Russian Federation on the Provision of State Services for the Implementation of Migration Registration of Foreign Citizens and Stateless Persons in the Russian Federation, Application Forms for Registration of a Foreign Citizen or Stateless Person at the Place of Residence, Notification of the Arrival of a Foreign Citizen or Stateless Person in the Place of Residence residence, registration marks of a foreign citizen or a stateless person at the place of residence, notes confirming the fulfillment by the host party and the foreign citizen of the actions necessary for his registration at the place of stay”;
Order of the Ministry of Internal Affairs of Russia dated 31.12.2017 No. 984 “On approval of the Administrative Regulations of the Ministry of Internal Affairs of the Russian Federation on the Provision of State Registration services for Citizens of the Russian Federation at the place of stay and at the place of Residence within the Russian Federation”;
Order of the Federal Migration Service of the Russian Federation No. 364 dated 29.08.2013 “On Approval of the Administrative Regulations for the Provision by the Federal Migration Service of State Services for the Implementation of Migration Registration in the Russian Federation”;
Order of the Federal Migration Service of the Russian Federation dated 11.09.2012 No. 288 “On Approval of the Administrative Regulations for the Provision by the Federal Migration Service of State Registration Services for Citizens of the Russian Federation at the Place of Stay and at the Place of Residence within the Russian Federation”;
Order of the Federal Migration Service of the Russian Federation dated 09/24/2014 No. 528 “On Approval of the Procedure for Submission by the Administrations of Hotels, Sanatoriums, Rest Homes, Boarding Houses, Campsites, Tourist Bases, Medical Organizations or Other Similar Institutions, Institutions of the Penal Enforcement System Executing Sentences in the Form of Imprisonment or Forced Labor, Information on Registration and Removal of Citizens of the Russian Federation from the Registration registration at the place of stay in the territorial bodies of the FMS of Russia”;
Order of the Ministry of Education and Science of the Russian Federation No. 1383 dated 27.11.2015 “On approval of the Regulations on the practice of students mastering the basic professional educational programs of higher education”;
Order of the Ministry of Education and Science of the Russian Federation No. 291 dated 18.04.2013 “On approval of the Regulations on the practice of students mastering the basic professional educational programs of secondary vocational education”;
The Charter of Oktagon LLC ;
Employment contracts with employees;
Contracts concluded between Oktagon LLC and the subject of personal data;
Contracts concluded between Oktagon LLC and persons processing personal data on behalf of Oktagon LLC;
Consent of the subjects to the processing of personal data.
VOLUME AND CATEGORIES OF PERSONAL DATA PROCESSED, CATEGORIES OF PERSONAL DATA SUBJECTS
The content and volume of the processed personal data of the Subjects corresponds to the purposes of processing.
As part of the processing of personal data of employees, the following categories of personal data are processed:
name, series, number, date of issue, direction or specialty, OKSO code, OKIN of the document on education, qualification or availability of special knowledge
profession (including OKPDTR code);
work experience;
marital status;
family composition, indicating the degree of kinship, surname, first name, patronymic, year of birth of the closest relatives;
data of the identity document (type, series, number, date of issue, name of the body that issued the document);
address and date of registration;
actual address of residence;
phone number;
information about the attitude to military service;
date of employment;
nature of work;
type of work (main, part-time);
structural division;
position (specialty, profession), category, class (category) of qualification;
previously held position;
tariff rate (salary), allowance, rub.
basis of employment;
employee’s personal signature;
electronic signature;
certification information (date, decision, document number and date, basis);
information about professional training (date of the beginning and end of retraining, specialty (direction, profession, name, number, date of the document certifying retraining, the basis of retraining);
information about awards, incentives, honorary titles (name, number, date of award);
information about vacations (type, period of work, number of days, start and end date, reason);
information about social benefits to which an employee is entitled in accordance with the law (name of the benefit, number, date of issue of the document, reason);
information about dismissal (grounds, date, number and date of the order);
scope of work;
information from the health certificate;
information from the driver’s license;
income information;
photo.
As part of the processing of personal data of employees, the following categories of personal data of relatives of employees are processed:
Surname First Name Patronymic;
Degree of kinship;
Year of birth.
As part of the processing of personal data of former employees, the categories of personal data specified in clause 4.3 of this Policy are processed;
As part of the processing of personal data of guests and their legal representatives, the following categories of personal data are processed:
Surname First Name Patronymic;
Citizenship;
Date of birth;
Gender;
Place of birth;
Registration address;
Address of the former place of residence in the Russian Federation;
data of the identity document (type, series, number, date of issue, name of the authority that issued the document);
information about the document confirming the right to stay in the Russian Federation (document type, series and number date of issue, validity period, category, multiplicity, purpose of entry into the Russian Federation);
information about the migration card (series and number, date of entry into the Russian Federation, period of stay, entry checkpoint);
purpose of the trip;
check-in date;
check-out date;
Profession;
Place of work;
Room number;
Phone;
E-mail.
As part of the processing of the interns’ personal data, the following categories of personal data are processed:
Surname First Name Patronymic;
Specialty;
Study group;
Dates of internship.
As part of the processing of students’ personal data, the following categories of personal data are processed:
Surname First Name Patronymic;
Date of birth;
data of the identity document (type, series, number, date of issue, name of the authority that issued the document);
Registration address;
SNILS;
INN;
Service number.
As part of the processing of contractors’ personal data, the following categories of personal data are processed:
Surname First Name Patronymic;
data of the identity document (type, series, number, date of issue, name of the authority that issued the document);
taxpayer identification number;
number and series of the insurance certificate;
bank account;
address of residence,
phone number;
details of the certificate of state registration as an individual entrepreneur.
As part of the processing of personal data of representatives/employees of contractors (legal entities), the following categories of personal data are processed:
Surname First Name Patronymic;
Place of work;
Position;
Phone number;
E-mail.
Octagon LLC does not process biometric personal data (information that characterizes the physiological and biological characteristics of a person, on the basis of which it is possible to establish his identity and which are used to establish the identity of the subject of personal data).
Oktagon LLC does not process special categories of personal data related to race, nationality, political views, religious or philosophical beliefs, health status, intimate life.
PROCEDURE AND CONDITIONS OF PERSONAL DATA PROCESSING
At Oktagon LLC, the processing of personal data of subjects is carried out for the purposes specified in section II of this Policy.
Octagon LLC processes the categories of personal data specified in section IV of this Policy.
The processing of personal data in Oktagon LLC is carried out only if the consent of the subjects of personal data is obtained. The consent of the subject of personal data is issued in writing, unless otherwise established by the Federal Law “On Personal Data”.
The processing of personal data of subjects includes the following actions: collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), deletion, destruction of personal data.
Oktagon LLC does not transfer personal data cross-border (on the territory of a foreign state to a foreign state authority, a foreign individual or a foreign legal entity).
Oktagon LLC has created publicly available sources of personal data (official websites). Personal data (surname, first name, patronymic, position, phone number) reported by the subject (employee/ citizen) are included in such sources only with the written consent of the subject of personal data.
Collection, recording, systematization, accumulation and clarification (updating, modification) of personal data is carried out by obtaining personal data directly from personal data subjects (their legal representatives).
Oktagon LLC and employees of Oktagon LLC who have gained access to personal data are obliged not to disclose to third parties and not to distribute personal data without the consent of the personal data subject, unless otherwise provided by federal law.
Oktagon LLC has the right to transfer personal data to the bodies of inquiry and investigation, other authorized bodies on the grounds provided for by the current legislation of the Russian Federation.
If the provision of personal data is mandatory in accordance with federal law, an employee of Oktagon LLC who collects (receives) personal data directly from personal data subjects is obliged to explain to the personal data subject the legal consequences of refusing to provide his personal data.
Oktagon LLC ensures compliance with the principles of personal data processing specified in Article 5 of Federal Law 152-FZ “On Personal Data” in its activities.
Oktagon LLC in its activities takes measures provided for in Part 2 of Article 18.1, Part 1 of Article 19 of Federal Law 152-FZ “On Personal Data”.
Octagon LLC does not use databases located outside the borders of the Russian Federation for processing personal data.
Conditions for termination of personal data processing by Oktagon LLC:
achievement of the purposes of personal data processing;
expiration of the consent or revocation of the consent of the personal data subject to the processing of his personal data;
identification of unlawful processing of personal data;
liquidation/reorganization of a legal entity;
loss of legal grounds for processing personal data.
The appointed persons of Oktagon LLC exercise control over the storage and use of material carriers of personal data, which does not allow unauthorized use, clarification, dissemination and destruction of personal data on these carriers.
The period of storage of personal data in a form that allows determining the subject of personal data is carried out no longer than the purposes of personal data processing require, except in cases when the period of storage of personal data is not established by federal law, an agreement to which the subject of personal data is a party, beneficiary or guarantor.
In order to comply with the legislation of the Russian Federation, to achieve the purposes of processing, as well as in the interests and with the consent of the subjects of personal data, Oktagon LLC provides personal data to the following organizations in the course of its activities:
Authorized organizations and officials within the established powers and competencies under federal law;
Authorized state bodies carrying out operational investigative activities or ensuring the security of the Russian Federation;
Licensing and/or controlling bodies of state power and local self-government;
Federal Tax Service;
Pension Fund of Russia;
Territorial office of the Federal Migration Service;
UPDATING, CORRECTION, DELETION AND DESTRUCTION OF PERSONAL DATA, RESPONSES TO REQUESTS OF SUBJECTS FOR ACCESS TO PERSONAL DATA
In case of detection of illegal processing of personal data, Oktagon LLC blocks illegally processed personal data.
In case of detection of inaccurate personal data, Oktagon LLC blocks the relevant personal data for the verification period. In case of confirmation of the fact of inaccuracy of personal data, Oktagon LLC, based on the information provided by the personal data subject or his representative or the authorized body for the protection of the rights of personal data subjects, or other necessary documents, clarifies personal data and removes the blocking of personal data.
Oktagon LLC is obliged to inform the subject of personal data or his representative of information about the processing of personal data of such subject carried out by him at the request of the latter.
Information concerning the processing of personal data is provided to the personal data subject or his representative upon receipt of a request from the personal data subject or his representative. The request can be sent in the form of an electronic document and signed with an electronic signature in accordance with the legislation of the Russian Federation.
Consideration of requests from personal data subjects or their representatives, as well as the authorized body for the protection of the rights of personal data subjects:
Personal data subjects have the right to receive information concerning the processing of their personal data, including information containing:
Confirmation of the fact of personal data processing in Oktagon LLC ;
Legal grounds and purposes of personal data processing;
The methods of personal data processing used in Oktagon LLC;
Processed personal data related to the relevant personal data subject, the source of their receipt, unless another procedure for submitting such data is provided for by federal law;
Terms of processing of personal data, including the terms of their storage in Oktagon LLC;
The procedure for the exercise by the subject of personal data of the rights provided for by the legislation of the Russian Federation in the field of personal data;
Other information provided by the legislation of the Russian Federation in the field of personal data.
Upon receipt of a request from a Personal data Subject or his representative, as well as the authorized body for the protection of the rights of personal data subjects, Oktagon LLC provides information within the time limits in accordance with the requirements of Article 20 of Federal Law No. 152-FZ of 27.07.2006 “On Personal Data”.
The subjects of personal data have the right to demand from Oktagon LLC the clarification of their personal data, their blocking or destruction if the personal data are incomplete, outdated, inaccurate, illegally obtained or are not necessary for the stated purpose of processing, as well as to take measures provided by law to protect their rights
The right of a personal data subject to access his personal data may be restricted in accordance with federal laws, including if the access of a personal data subject to his personal data violates the rights and legitimate interests of third parties.
In order to obtain the necessary information regarding the processing of personal data described in paragraph 6.5.1. of this Policy, the Subject (or legal representative) must fill out the appropriate form for requesting the subject of personal data for information related to the processing of personal data (Appendix 1 or 5) and hand it over personally to the employees of Oktagon LLC receiving citizens’ appeals, or by mail.
In order to clarify certain personal data, the Subject (or legal representative) must fill out the appropriate form of the personal data subject’s request for clarification of personal data (Appendix 2 or 6) and hand it over personally to the employees of Oktagon LLC who accept citizens’ appeals, or by mail.
To exclude the illegality of the processing of personal data, the Subject (or legal representative) must fill out the appropriate form of the request of the subject of personal data for the destruction of personal data (Appendix 3 or 7) and hand it over personally to the employees of Oktagon LLC who receive citizens’ appeals, or by mail.
In order to revoke the consent of the Personal data Subject to the processing of his personal data, the subject (or legal representative) must fill out the appropriate form for revoking the consent of the personal data subject to the processing of his personal data (Appendix 4 or 8) and hand it over personally to the employees of Oktagon LLC who accept citizens’ appeals, or by mail. In case of withdrawal of consent to the processing of personal data, Oktagon LLC has the right to continue processing personal data without the consent of the personal data subject if there are grounds specified in paragraphs 2-11 of Part 1 of Article 6, Part 2 of Article 10 and Part 2 of Article 11 of Federal Law No. 152—FZ of 27.07.2006 “On Personal Data”.
Upon achievement of the purposes of personal data processing, as well as in the case of withdrawal by the subject of personal data of consent to their processing, personal data are subject to destruction if:
Nothing else is provided for in the contract to which the subject of personal data is a party, beneficiary or guarantor;
Nothing else is provided for by another agreement between Oktagon LLC and the subject of personal data.
Upon receipt of a request from a Personal data Subject or his representative, as well as the authorized body for the protection of the rights of personal data subjects, for the elimination of violations of the law committed during the processing of personal data, for the clarification, blocking and destruction of personal data, Oktagon LLC takes appropriate measures and notifies of the measures taken in time according to the requirements of Article 21 of the Federal Law the Law of 27.07.2006 N 152-FZ “On personal data”.
FINAL PROVISIONS
This policy is an internal document of Oktagon LLC, publicly available and subject to posting on the official website of Oktagon LLC.
This policy is subject to change, addition in the event of new legislative acts and special regulatory documents on the processing and protection of personal data, but at least once every three years.
Control over the fulfillment of the requirements of this policy is carried out by the person responsible for organizing the processing of personal data in Oktagon LLC.
The responsibility of the officials of Oktagon LLC who have access to personal data for non-compliance with the requirements of the norms governing the processing and protection of personal data is determined in accordance with the legislation of the Russian Federation and the internal documents of Oktagon LLC.
