1. Protection of Personal Data
1.1) Personal data:
Some of the information contained in our databases are personally data (“Personal Data”), covered by European Directive 95/46/EC dated 24 October 1995 “on the protection of individuals with regard to the processing of personal data, and on the free movement of such data”, and by the French Act no.78-17 of 6 January 1978, the so-called Data Protection Law (“Data Protection Law”), as amended by the Act of 6 August 2004. All Personal Data, as defined in the Data Protection Law, contained in our databases was or will be collected in accordance with the requirements of the Data Protection Law. Personal Data is collected only after informing the people who are concerned.
1.2) Sensitive personal data:
We undertake not to collect, store, sell, transfer or use Sensitive Personal Data, as defined by the European Directive 95/46/EC of 24 October 1995 and the Data Protection Law of 6 January 1978.
1.3) Transfer of personal data within the European Economic Area :
We shall not be obliged to supply Personal Data outside the territory of the European Economic Area (EEA) (i.e. 27 Member States territory including Iceland, Liechtenstein and Norway). However we may authorize such a transfer provided that French and European laws in force are observed. We have a written group policy on the personal data export.
We conduct internal audits of our affiliates on data protection requirements in accordance with the Data Protection Law and follow up action plans.
1.5) Confidentiality of Personal Data
All our employees, service providers and partners enter into a confidentiality agreement with us.
2. Security of Personal Data
2.1) Physical security
We have adequate physical security to protect the computing facilities and paper documents that contain Personal Data including locked file cabinets, secure buildings, and secure rooms.
2.2) Standard Operating Procedures (SOPs) for physical security
Firewalls are installed to guarantee security of access to Personal Data. The firewalls operations protocols are kept up to date. Prevention of intrusions and detection of intruders is performed through an instructions book. Corrective patches for the firewall are only installed after they have been verified. Remote connexion requires an user ID and password.
2.4) Intrusion detection software
We use intrusion detection software to protect Personal Data.
Antivirus software is installed to ensure the protection and integrity of systems and sub-systems. An anti-virus product is placed on incoming and outgoing email. Updating is daily and automatic daily update. An Antivirus product is placed on Internet flows, with an automatic daily update. The antivirus on the Windows workstations and the server is constantly active and is updated on a daily basis.
2.6) Standard Operating Procedures (SOPs) for the use of security technology and transfers
We have SOPs in writing and implemented that cover the use of security technology used to protect data repositories, servers, data transfers, intrusion detection software and virus protection software.
3. Duration of Storage of Personal Data
Cegedim complies with the limited duration of data storage in accordance with the French Data Protection Law.
4. Business Partners Information
Cegedim informs its business partners that they can have access, oppose to, modify and refuse any communication of their Personal data in accordance with the French Data Protection Law.
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