General data protection regulation (GDPR) compliance for Aston VIP
With Aston VIP
Global Expertise
1. Introduction
Aston VIP is firmly committed to ensuring the privacy and security of its customers' personal data in strict compliance with the General Data Protection Regulation (EU) 2016/679 (GDPR). This foundational document outlines Aston VIP's detailed approach to GDPR compliance, specifying the legal, technical, and organizational measures implemented to safeguard personal data, foster transparency, and uphold the trust of our clients, employees, and partners. By adhering to the GDPR's requirements, Aston VIP reinforces its commitment to data protection as a cornerstone of its operational and ethical framework.
The GDPR represents a paradigm shift in the way personal data is handled, ensuring that individuals retain greater control over their data while requiring organizations to implement robust mechanisms for accountability and transparency. At Aston VIP, compliance with GDPR is not merely a legal requirement but a strategic priority integrated into every aspect of our operations. This document elaborates on how Aston VIP ensures that personal data is handled responsibly and ethically, thereby aligning with the highest standards of data protection and privacy.
1. Data protection principles
We only share your data when necessary, ensuring compliance with all applicable laws and regulations:
1.1. Processed lawfully, fairly, and transparently
Personal data is handled in full compliance with applicable laws, ensuring fairness and transparency in all processing activities. Aston VIP provides clear and accessible information to data subjects about how their data is collected, processed, stored, and shared. This includes providing detailed privacy notices and obtaining explicit consent where necessary.
1.2. Collected for specified, explicit, and legitimate purposes
Data is gathered only for purposes that are clearly defined and communicated to data subjects at the time of collection. Aston VIP ensures that personal data is not processed for any secondary or unrelated purposes unless explicit consent is obtained or such processing is legally permissible under GDPR.
1.3. Adequate, relevant, and limited to what is necessary
The principle of data minimisation is strictly adhered to, ensuring that only data directly relevant and necessary for the specified purposes is collected. This avoids the accumulation of excessive or redundant information, reducing the risk of misuse or unauthorised access.
1.4. Accurate and, where necessary, kept up-to-date
Aston VIP takes active steps to maintain the accuracy and completeness of personal data. Regular reviews and updates ensure that outdated, incorrect, or incomplete data is corrected or deleted promptly. Data subjects are provided with mechanisms to update their information easily.
1.5. Kept in a form that permits identification of data subjects for no longer than necessary
Personal data is stored only for the duration required to fulfil its intended purpose or comply with legal and regulatory requirements. Aston VIP enforces strict retention policies, ensuring that data is securely deleted or anonymised when it is no longer needed, thereby minimising risks to data subjects.
1.6. Processed in a manner that ensures appropriate security of the personal data
Robust technical and organisational measures are implemented to protect personal data against unauthorised or unlawful processing, accidental loss, destruction, or damage. This includes the use of encryption, secure storage solutions, access controls, and regular security assessments. Aston VIP ensures that all personnel handling personal data are trained and aware of their responsibilities under GDPR.
By embedding these principles into its operational and governance frameworks, Aston VIP demonstrates its unwavering commitment to data protection, ensuring that data subjects’ rights are respected and safeguarded at all times.
2. Legal basis for data processing
Aston VIP processes personal data based on one or more of the following legal bases, in accordance with the requirements of the GDPR.
2.1. Consent
Explicit consent is obtained from data subjects prior to the processing of their personal data. This consent is informed, specific, and freely given, ensuring that data subjects have a clear understanding of how their data will be used. Aston VIP maintains records of all consents and provides mechanisms for data subjects to withdraw their consent at any time without detriment.
2.2. Contractual necessity
Processing is carried out when it is necessary for the performance of a contract to which the data subject is a party, or to take pre-contractual steps requested by the data subject. This includes scenarios such as providing services or fulfilling contractual obligations.
2.3. Legal obligation
Aston VIP processes personal data when it is necessary to comply with legal or regulatory obligations. This includes obligations under tax laws, employment regulations, or other statutory requirements applicable to the organisation’s operations.
2.4. Legitimate interests
Processing is undertaken to fulfil Aston VIP’s legitimate business interests, provided that these interests do not override the fundamental rights and freedoms of data subjects. Legitimate interests may include activities such as improving services, conducting direct marketing, or ensuring network security. Aston VIP conducts thorough assessments to balance its interests against the rights of data subjects, ensuring that their privacy is not adversely affected.
3. Data subjects' rights
Aston VIP recognises and upholds the rights of data subjects under GDPR, ensuring that individuals maintain control over their personal data and how it is used. These rights include:
3.1. Right to be informed
Data subjects have the right to clear, concise, and transparent communication regarding the processing of their personal data. Aston VIP ensures that all necessary information, including purposes of processing and data retention periods, is provided in an easily accessible manner.
3.2. Right of access
Data subjects can request access to their personal data held by Aston VIP, including details about the purposes of processing, categories of data processed, and any third-party recipients. Requests are handled promptly and transparently.
3.3. Right to rectification
Inaccurate or incomplete data will be corrected or supplemented without undue delay. Aston VIP provides mechanisms for data subjects to submit corrections or updates to their information.
3.4. Right to erasure ("right to be forgotten")
Data subjects can request the deletion of their personal data when it is no longer necessary for the purposes for which it was collected, or if consent is withdrawn. Aston VIP honours such requests unless retention is required by law or necessary for legal claims.
3.5. Right to restrict processing
Data subjects can request that processing of their personal data be restricted under specific circumstances, such as when the accuracy of the data is contested or processing is unlawful.
3.6. Right to data portability
Data subjects have the right to receive their personal data in a structured, commonly used, and machine-readable format. They can also request the transfer of their data to another data controller where technically feasible.
3.7. Right to object
Data subjects can object to processing activities based on legitimate interests or direct marketing purposes. Aston VIP assesses such objections and ceases processing unless compelling legitimate grounds are demonstrated.
3.8. Rights related to automated decision-making and profiling
Where processing involves automated decision-making, including profiling, Aston VIP ensures that safeguards are in place to protect the rights and freedoms of data subjects. Individuals have the right to request human intervention and to challenge decisions.
4. Data collection and usage
Aston VIP collects and processes personal data to deliver its services effectively, comply with legal obligations, and enhance operational efficiency. The following sections outline the types of data collected, the purposes for their collection, and how they are used within the framework of GDPR compliance.
4.1. Customer information
Customer information encompasses a wide range of personal data necessary for service provision. This includes:
Personal details
Such as name, address, date of birth, and contact information (email address and phone number).
Financial data
Including payment details such as credit card information, bank account details, and transaction history to facilitate billing and refunds.
Service-related data
Data collected to customise services, address customer queries, and provide account management support
This information is essential for establishing and maintaining customer relationships, fulfilling contractual obligations, and ensuring the effective delivery of Aston VIP’s services.
4.2. Website data
Data collected through Aston VIP’s website enhances user experience, supports analytics, and optimises service delivery. This includes:
Cookies
Small data files stored on users’ devices to personalise their browsing experience and remember preferences.
IP addresses
Used to identify geographic locations for tailored content delivery and fraud prevention.
Browsing behaviour
Analysed to understand user interaction with the website, improving design and functionality.
Visitors are informed about data collection on the website through a comprehensive cookie policy and consent banners. Users are given options to manage or reject cookies according to their preferences.
4.3. Employee data
To ensure efficient human resource management and compliance with labour laws, Aston VIP collects and processes employee data, which includes:
Personal information
Such as name, contact details, and national identification numbers.
Employment details
Including employment contracts, job roles, and performance evaluations.
Payroll data
For salary processing, tax calculations, and benefits administration.
Health and safety records
Necessary for maintaining workplace safety and legal compliance.
This data enables Aston VIP to manage its workforce effectively while ensuring that employee rights and data protection requirements are upheld.
4.4. Third-party data
Aston VIP works with various partners, vendors, and service providers, processing data shared by these entities in a secure and GDPR-compliant manner. This includes:
Supplier data
Such as contact information, contracts, and transaction details required for business operations.
Partner data
Shared for collaboration, joint ventures, or marketing purposes, with explicit agreements to ensure confidentiality and compliance.
Client-provided data
Data shared by clients regarding their customers or operations for specific services offered by Aston VIP.
Aston VIP ensures that all third-party data is processed only for the agreed-upon purposes, with appropriate safeguards to maintain its security and confidentiality.
4.5. Purpose and retention
All data collected by Aston VIP is used exclusively for legitimate purposes, including:
- Delivering and improving services.
- Fulfilling contractual and legal obligations.
- Enhancing customer satisfaction and engagement.
- Conducting analytics and research for business growth.
For a detailed explanation of our KYC process, please refer to our KYC Policy.
Data is retained only for as long as necessary to achieve these purposes or to comply with statutory requirements. Once data is no longer required, it is securely deleted or anonymised in accordance with Aston VIP’s data retention policy.
5. Data security measures
Aston VIP collects and processes personal data to deliver its services effectively, comply with legal obligations, and enhance operational efficiency. The following sections outline the types of data collected, the purposes for their collection, and how they are used within the framework of GDPR compliance.
5.1. Technical measures
To protect sensitive data, Aston VIP employs state-of-the-art technical solutions, which include:
Encryption
Sensitive data is encrypted both during storage and transmission using industry-standard protocols, ensuring that unauthorised parties cannot access the information.
Secure servers and networks
Firewalls, intrusion detection systems, and endpoint protection tools are implemented to safeguard data from external threats.
Data masking
Personally identifiable information is replaced with anonymised tokens where feasible, limiting exposure during processing.
Backup and recovery systems
Regular backups of critical data are maintained, with robust disaster recovery plans to ensure continuity in the event of a technical failure.
Regular security audits
Comprehensive audits are conducted to identify vulnerabilities and verify compliance with data security standards.
Vulnerability assessments and penetration testing
Regular testing is performed to evaluate the resilience of Aston VIP’s systems against potential cyber threats.
5.2. Organisational measures
Aston VIP reinforces data security through effective organisational practices, including:
Employee training
All employees receive regular training on data protection principles, GDPR compliance, and security best practices, ensuring awareness of their responsibilities.
Access control policies
Strict role-based access controls are implemented, limiting data access to authorised personnel only. Permissions are reviewed periodically to maintain minimal access rights.
Confidentiality agreements
Employees, contractors, and third-party partners are required to sign confidentiality agreements, binding them to protect the data they handle.
Data governance policies
Clear policies govern the collection, processing, and retention of data, ensuring alignment with legal and regulatory requirements.
Monitoring and logging
Continuous monitoring of systems and detailed logging of data access events help detect and address potential security issues promptly.
5.3. Incident response
Aston VIP has established a comprehensive incident response framework to address data breaches and security incidents effectively.
Detection mechanisms
Automated systems monitor for suspicious activities, unauthorised access attempts, and potential breaches in real-time.
Reporting protocols
Incidents are reported internally to the designated Data Protection Officer (DPO) and externally to supervisory authorities within the required 72-hour timeframe when applicable.
Containment strategies
Immediate steps are taken to isolate affected systems, prevent further data loss, and mitigate potential damage.
Investigation and root cause analysis
A thorough investigation is conducted to identify the cause of the breach and implement corrective actions to prevent recurrence.
Communication with affected parties
Where required, Aston VIP promptly notifies affected data subjects, providing clear information on the nature of the breach and steps being taken to safeguard their data.
Post-incident review
Lessons learned from incidents are documented and used to enhance Aston VIP’s security policies and practices.
6. Data retention policy
Aston VIP recognises the importance of adhering to data retention practices that align with GDPR principles and operational efficiency. The organisation is committed to retaining personal data only for as long as it is necessary to fulfil the purposes for which it was collected or to comply with legal, contractual, or regulatory obligations. This policy ensures that data is handled responsibly, securely, and with due regard for privacy.
6.1. Purpose-driven retention
Data retention at Aston VIP is guided by the specific purposes for which the data was collected. Personal data is stored only for the duration necessary to:
- Provide services and maintain customer relationships.
- Comply with legal and regulatory requirements.
- Resolve disputes or enforce contractual agreements.
- Conduct business analyses or statistical research, where anonymisation is applied whenever possible.
6.2. Retention schedules
Aston VIP has established clear retention schedules tailored to different types of data:
Customer data
Retained for the duration of the customer relationship and a predefined period thereafter to address potential queries, disputes, or legal requirements.
Employee data
Stored in accordance with employment laws and regulations, including payroll records, tax information, and performance data.
Website data
Cookies and browsing data are retained for the minimum period required to optimise user experience and conduct analytics, in compliance with consent preferences.
Third-party data
Retained based on the terms of agreements or for the duration necessary to fulfil the agreed purposes.
6.3. Secure deletion and anonymisation
When data is no longer required for its intended purpose, Aston VIP ensures its secure disposal or anonymisation:
Deletion protocols
Personal data is permanently erased from all systems and backups using industry-standard methods to prevent recovery.
Anonymisation
Data is rendered anonymous where it may be beneficial for research or analytical purposes, removing all personally identifiable information.
Hardware disposal
Devices and storage media containing sensitive data are securely wiped or destroyed when decommissioned.
6.4. Legal and regulatory compliance
Certain data may be retained longer if required by law or regulatory obligations. Examples include:
- Financial and tax records retained for audit and statutory reporting.
- Employment records kept in compliance with labour laws.
- Records related to legal disputes or investigations, preserved until resolution.
6.5. Retention reviews
Aston VIP conducts regular reviews of its data retention practices to ensure compliance and relevance:
- Retention schedules are assessed periodically to reflect changes in legal requirements or business needs.
- Data that exceeds its retention period is flagged for secure deletion or anonymisation.
- Documentation of retention decisions ensures accountability and transparency.
7. Third-party processors
Aston VIP collaborates with various third-party processors to deliver its services and meet operational objectives effectively. Recognising the critical role these entities play in data processing activities, Aston VIP ensures that all third-party processors strictly adhere to GDPR standards and maintain the highest levels of data protection. The following measures and practices outline how Aston VIP manages relationships with third-party processors.
7.1. Due diligence
Before engaging a third-party processor, Aston VIP conducts a thorough due diligence assessment to evaluate the processor’s:
- Data protection policies and procedures.
- Technical and organisational measures for safeguarding personal data.
- History of compliance with GDPR and other relevant regulations.
- Ability to handle data securely and reliably.
7.2. Contractual agreements
Aston VIP enters into detailed contractual agreements with all third-party processors, ensuring compliance with GDPR Article 28. These agreements include:
Data processing instructions
Clearly defined roles and responsibilities for processing personal data.
Confidentiality obligations
Binding clauses that ensure the processor’s personnel maintain the confidentiality of the data they handle.
Security requirements
Obligations to implement robust technical and organisational measures to protect data against breaches and unauthorised access.
Sub-processor approval
Written consent from Aston VIP is required before engaging any sub-processors.
Data return or deletion
At the end of the processing relationship, the processor must either return or securely delete all personal data.
7.3. Regular compliance reviews
Aston VIP conducts ongoing compliance monitoring to ensure third-party processors maintain GDPR standards. This includes:
- Periodic audits and assessments to verify adherence to contractual obligations.
- Evaluation of the processor’s security measures and incident response protocols.
- Monitoring for changes in the processor’s policies, practices, or circumstances that may impact compliance.
7.4. Incident management
Third-party processors are required to notify Aston VIP immediately in the event of a data breach or security incident. Aston VIP works collaboratively with processors to:
- Contain and mitigate the impact of the incident.
- Investigate the root cause and implement corrective actions.
- Notify data subjects and supervisory authorities if required under GDPR.
7.5. Transparency and accountability
Aston VIP maintains detailed records of all third-party processing activities, including:
- The categories of data processed.
- The purposes of processing and associated legal bases.
- Details of all processors and sub-processors involved.
- Measures implemented to safeguard data.
This documentation ensures transparency and provides a robust framework for demonstrating accountability in data processing activities.
7.6. Termination protocols
When the relationship with a third-party processor concludes, Aston VIP ensures:
- Secure return or deletion of all personal data as outlined in contractual agreements.
- Revocation of any system access granted to the processor.
- Final compliance review to confirm that data protection standards were maintained throughout the relationship.
8. Data protection officer (DPO)
Aston VIP has appointed a dedicated Data Protection Officer (DPO) to ensure compliance with GDPR and safeguard personal data. The DPO serves as a central point of contact for any data protection queries or concerns, both within the organisation and for external stakeholders. Their role is integral to Aston VIP’s commitment to privacy and accountability.
8.1. Responsibilities of the DPO
The DPO oversees Aston VIP’s data protection activities to ensure they meet legal and regulatory standards. Specific responsibilities include:
- Monitoring compliance with GDPR and other data protection laws.
- Advising on data protection impact assessments and other privacy-related matters.
- Conducting regular audits and reviews of data handling practices.
- Providing guidance and training to staff on data protection policies.
- Responding to enquiries and complaints from data subjects and external authorities.
- Assisting with incident management, including breach notifications and remedial actions.
8.2. DPO contact details
For any questions or concerns related to data protection or your personal data, you can contact Aston VIP’s Data Protection Officer using the following details:
Aston VIP data protection officer
-
Email
contact@aston.ae -
Phone
+44 20 3885 8150 -
Address
Aston VIP, London, United Kingdom
8.3. Support and confidentiality
The DPO is committed to addressing all queries in a timely and professional manner, ensuring confidentiality and transparency throughout the process. Whether it is a general question about data handling or a specific concern regarding your rights, the DPO is here to assist.
8.4. Ensuring accountability
The DPO provides regular updates to Aston VIP’s leadership, highlighting areas for improvement and ensuring that data protection remains a priority. By fostering a culture of accountability, Aston VIP ensures ongoing compliance and enhances trust with its clients and partners.
8.5. Independence of the DPO
The DPO operates independently, ensuring impartial advice and oversight of Aston VIP’s data processing practices. This independence guarantees that decisions and recommendations are made in the best interest of protecting personal data.
Aston VIP’s appointment of a dedicated Data Protection Officer underscores its commitment to safeguarding personal data and upholding the highest standards of privacy and security. If you have any questions, please do not hesitate to reach out.
9. International data transfers
Aston VIP recognises that transferring personal data across international borders requires robust safeguards to protect the rights and freedoms of data subjects. When personal data is transferred outside the European Economic Area (EEA), Aston VIP ensures that these transfers are carried out in full compliance with GDPR requirements, employing measures to uphold the same level of data protection as provided within the EEA.
9.1. Adequacy decisions by the European Commission
Aston VIP transfers personal data to countries or territories that have been deemed by the European Commission to provide an adequate level of data protection. These adequacy decisions ensure that the recipient country’s legal framework offers privacy safeguards equivalent to GDPR standards. Examples include countries such as Switzerland and Japan. Transfers to these regions require no additional authorisation or agreements.
9.2. Standard contractual clauses (SCCs)
For data transfers to countries without an adequacy decision, Aston VIP relies on standard contractual clauses approved by the European Commission. These legally binding agreements between Aston VIP and the recipient entity impose contractual obligations to maintain GDPR-compliant data protection standards. SCCs cover various aspects, including:
- Clear data processing instructions.
- Security requirements to prevent unauthorised access.
- Obligations to notify Aston VIP in the event of a data breach.
Aston VIP regularly reviews these agreements to ensure ongoing compliance with GDPR updates and regulatory developments.
9.3. Other legally recognised mechanisms
In addition to adequacy decisions and SCCs, Aston VIP may employ other mechanisms recognised under GDPR, such as:
Binding corporate rules (BCRs)
Used for intra-group data transfers within multinational companies, ensuring uniform data protection practices across all entities.
Explicit consent
Data subjects are informed of the transfer risks and provide their explicit consent prior to the transfer.
Derogations for specific situations
These are used on an exceptional basis, such as when the transfer is necessary to fulfil a contract or protect the vital interests of the data subject.
9.4. Technical and organisational safeguards
Regardless of the transfer mechanism used, Aston VIP implements additional technical and organisational measures to enhance data security, including:
Data encryption
Ensuring that data is encrypted during transfer to prevent unauthorised interception.
Access controls
Limiting access to personal data only to authorised personnel or entities with a legitimate purpose.
Data minimisation
Transferring only the data necessary for the specific purpose, reducing exposure to risks.
9.5. Transparency and accountability
Aston VIP maintains detailed records of all international data transfers, documenting the transfer mechanisms, purposes, and safeguards in place. Data subjects are informed about these transfers through privacy notices, providing clarity on where their data is processed and how it is protected.
9.6. Monitoring and review
Aston VIP continuously monitors changes in international data protection laws and regulatory guidance to ensure ongoing compliance. Regular audits and risk assessments are conducted to identify and mitigate potential risks associated with data transfers. By adhering to these practices, Aston VIP ensures that personal data transferred outside the EEA is protected to the highest standards, fostering trust and demonstrating its commitment to privacy and compliance.
10. Data breach management
Aston VIP places the utmost importance on responding swiftly and effectively to any data breaches to minimise impact and ensure compliance with GDPR. The organisation has established a comprehensive data breach management framework designed to detect, report, and mitigate breaches in a structured and timely manner. Below are the key steps and measures implemented to handle data breaches effectively.
10.1. Notification to the relevant supervisory authority
In compliance with GDPR Article 33, Aston VIP ensures that any data breach is reported to the appropriate supervisory authority within 72 hours of becoming aware of the breach, unless it is unlikely to result in a risk to the rights and freedoms of individuals. The notification includes:
- A description of the nature of the breach, including the categories and approximate number of affected data subjects and records.
- The likely consequences of the breach.
- Measures taken or proposed to address the breach and mitigate its adverse effects.
- The contact details of the Data Protection Officer (DPO) for further information.
If a breach occurs outside normal working hours, Aston VIP’s incident response team is equipped to manage the situation promptly to meet the 72-hour deadline.
10.2. Communication with affected data subjects
If the breach poses a high risk to the rights and freedoms of affected individuals, Aston VIP notifies the data subjects without undue delay. This communication includes:
- A description of the nature of the breach, including the categories and approximate number of affected data subjects and records.
- The likely consequences of the breach.
- Measures taken or proposed to address the breach and mitigate its adverse effects.
- The contact details of the Data Protection Officer (DPO) for further information.
Where direct communication is not feasible, Aston VIP uses public announcements or other appropriate measures to inform affected individuals effectively.
10.3. Implementation of corrective measures
Aston VIP is committed to identifying the root cause of any data breach and implementing corrective actions to prevent recurrence. Measures include:
Investigation and analysis
A thorough investigation is conducted to determine the breach's cause, scope, and impact.
System updates
Vulnerabilities identified during the investigation are addressed through system patches, upgrades, or replacements.
Policy reviews
Existing data protection policies and procedures are reviewed and updated as necessary to address any gaps.
Employee training
Targeted training sessions are conducted to address the breach's root cause and prevent similar incidents.
10.4. Incident logging and reporting
All data breaches are documented in Aston VIP’s incident log, which includes:
- The facts surrounding the breach.
- Its effects on data subjects and the organisation.
- Remedial actions taken to address the incident.
This documentation serves as an essential tool for internal review, supervisory authority audits, and continuous improvement of breach management practices.
10.5. Collaboration with third parties
In cases where third-party processors or partners are involved in the breach, Aston VIP works closely with them to:
- Contain the breach and secure affected data.
- Ensure their compliance with contractual and regulatory obligations.
- Incorporate their input into the breach investigation and resolution process.
10.6. Post-incident review
After resolving a breach, Aston VIP conducts a post-incident review to:
- Evaluate the effectiveness of the response and identify lessons learned.
- Enhance its breach management framework and security measures.
- Strengthen overall organisational resilience against future incidents.
11. Policy updates
Aston VIP is committed to maintaining its GDPR policy as a living document, ensuring that it evolves alongside changes in legislation, regulatory guidance, and organisational practices. Regular reviews and updates are essential to sustaining compliance, addressing emerging risks, and reflecting the latest developments in data protection standards.
11.1. Regular review schedule
This GDPR policy is subject to a comprehensive review at least once annually. Additionally, interim reviews are conducted in response to:
- Changes in relevant laws, regulations, or case law.
- Updates to guidance issued by supervisory authorities or the European Data Protection Board (EDPB).
- Introduction of new technologies or business processes affecting data protection.
- Lessons learned from data breaches, incidents, or audits.
11.2. Stakeholder involvement
Aston VIP ensures that key stakeholders are involved in the policy update process. This includes:
- The Data Protection Officer (DPO), who provides expertise and oversight.
- Legal and compliance teams, who review alignment with regulatory requirements.
- IT and security teams, who assess technical implications and safeguards.
- Operational leaders, who ensure that policy updates are practical and effective.
11.3. Change management process
Policy updates follow a structured change management process to maintain clarity and transparency:
Drafting revisions
Proposed updates are documented and reviewed internally.
Impact assessment
Changes are assessed for their impact on data subjects, processes, and compliance obligations.
Approval
The revised policy is approved by senior management to ensure alignment with Aston VIP’s strategic goals.
Communication
Updates are communicated clearly to employees, partners, and other stakeholders through training sessions, email notifications, and internal platforms.
11.4. Availability of the latest version
The most recent version of this GDPR policy is always accessible to stakeholders via Aston VIP’s official website. This ensures transparency and allows data subjects to stay informed about how their personal data is protected. The policy is available at:
11.5. Record-keeping and historical versions
Aston VIP maintains an archive of previous policy versions, ensuring that changes over time can be tracked and referenced if required. This practice supports accountability and provides a record of the organisation’s commitment to continuous improvement in data protection.
11.6. Employee training and awareness
Whenever the GDPR policy is updated, all relevant employees receive training to ensure they understand the changes and their implications. This reinforces compliance and fosters a culture of accountability and vigilance regarding data protection.
11.7. Feedback and suggestions
Aston VIP values feedback from employees, clients, and other stakeholders regarding its GDPR policy. Suggestions for improvement can be submitted to the Data Protection Officer (DPO) via email at contact@aston.ae.
Appendices
Appendix A: Data inventory
Aston VIP maintains a comprehensive inventory of all personal data it collects, processes, and stores. This inventory includes:
Encryption
Customer information, website data, employee data, and third-party data.
Sources
Details on how the data is collected, such as through forms, interactions, or third-party transfers.
Purposes
Specific reasons for processing, such as service provision, legal compliance, or analytics.
Retention periods
The duration for which each data type is retained, aligned with the data retention policy.
Security measures
Technical and organisational safeguards applied to protect the data.
The data inventory is regularly reviewed and updated to reflect changes in processing activities, ensuring accountability and compliance with GDPR.
Appendix A: Data inventory
Aston VIP enters into data processing agreements (DPAs) with all third-party processors to ensure GDPR compliance. Key elements of these agreements include:
Processing scope
Clear definitions of the data categories, processing purposes, and duration.
Security obligations
Requirements for implementing appropriate technical and organisational measures.
Data subject rights
Processes for assisting Aston VIP in fulfilling data subject requests.
Audit rights
Provisions for Aston VIP to audit the processor’s compliance with GDPR.
Termination
Conditions under which data must be returned or securely deleted upon termination of the agreement.
All DPAs are reviewed periodically to ensure alignment with regulatory updates and organisational needs.
Appendix C: Incident response procedures
Aston VIP has established detailed procedures for responding to data breaches and security incidents. These procedures include:
Detection
Continuous monitoring systems to identify potential breaches promptly.
Notification
Steps to notify the supervisory authority within 72 hours and communicate with affected data subjects if required.
Containment
Immediate measures to isolate the affected systems or data to prevent further exposure.
Investigation
A thorough analysis to determine the breach’s cause, impact, and affected individuals.
Remediation
Actions to address vulnerabilities and enhance security measures to prevent recurrence.
Documentation
Detailed records of all incidents, including the nature of the breach, response actions, and outcomes.
These procedures are regularly tested and updated to ensure their effectiveness in mitigating risks and protecting data subjects.
This document serves as the foundation of Aston VIP's GDPR compliance strategy, demonstrating our unwavering commitment to data protection and privacy. By adhering to these principles and practices, Aston VIP ensures the highest standards of transparency, accountability, and trust in all its data handling activities.
Aston VIP is committed to transparency and accessibility in addressing inquiries or concerns related to this GDPR policy.
Our dedicated team, including the Data Protection Officer (DPO), is available to provide prompt assistance and ensure that your privacy concerns are handled with the utmost care and professionalism. We encourage all stakeholders to reach out with feedback or queries, as your trust and confidence are vital to our commitment to data protection.
Contact us – we’re ready to assist you!
For any inquiries, clarifications, or assistance, please contact Aston VIP via email or by phone. Our team is available to provide support and address your concerns promptly.
Prefer messaging? Contact us through messengers or simply give us a call: Our working hours: Monday to Friday, 9 AM – 6 PM CET
Saved monthly
Stay updated with our latest articles
We stay up-to-date with the latest news regarding business and company formation in Dubai, UAE
Crypto & VARA
March 27, 2025
Company Formation
March 27, 2025
UAE
March 27, 2025
Crypto & VARA
March 27, 2025
Company Formation
March 27, 2025
UAE
March 27, 2025
Economic Growth
March 25, 2025
UAE
March 25, 2025
Economic Growth
March 23, 2025