Preface

In our company, we consider our duty to preserve and protect all personal data we have and/or process. Nevertheless, despite all the measures we take, there can be a breach of security, leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data, whether by accidental or deliberate causes. That is why we put in place a Data Breach Procedure.

What is a Data Breach

Personal data breaches can include the following: • access to personal data by an unauthorised third party; • deliberate or accidental action (or inaction) by a controller or processor; • sending personal data to an incorrect recipient; • hand-held devices / laptops containing personal data being lost or stolen; • alteration of personal data without permission; and • loss of availability of personal data.

Responsibility

It is the responsibility of everyone at our company to ensure they keep personal data safe. In the event that you are aware of a security breach, you must act fast and ensure you follow the procedure below. If you believe you may have encountered a data breach, you must report it using the form below and send this to the DPO at: [email protected]

Data Breach Workflow

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If needed, use this form to report a breach

Data Breach Reporting Form.docx

🛡️ Data Breach Response Procedure

1. Purpose

To establish a comprehensive, structured, and timely approach for identifying, assessing, managing, and mitigating personal data breaches, ensuring full compliance with the General Data Protection Regulation (GDPR) and other applicable legal, regulatory, and contractual obligations. This document also outlines communication protocols, collaboration with internal and external stakeholders, and the integration of lessons learned to improve future readiness. The procedure applies both to breaches involving REBORRN’s own data (as a data controller) and to breaches involving clients' data where REBORRN acts as a data processor.

2. Definitions

Personal Data Breach: Any breach of security that leads to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored or otherwise processed.
High Risk: A breach that is likely to result in a high risk to the rights and freedoms of individuals. Such risks may include identity theft, fraud, reputational damage, or loss of confidentiality.