HTT follows the European Commission data Protection Laws (GDPR)

What is GDPR?
The General Data Protection Regulation (GDPR) (EU) 2016/679 is a regulation in EU law on data protection and privacy 
for all individuals within the European Union. ... 
GDPR took effect, and replaceed the 1995 Data Protection Directive (Directive 95/46/EC). It was adopted on 27 April 2016.

The reform is an essential step to strengthening citizens' fundamental rights in the digital age and facilitating business 
by simplifying rules for companies in the Digital Single Market.

HTT  don't keep any personal information which could or would require any permission within EU. All information held 
by HTT is held confidentially and is protected by the EU Legislation 2018.

Data protection officer
If the processing is carried out by a public authority, except for courts or independent judicial authorities when acting in 
their judicial capacity or if, in the private sector, processing is carried out by a controller whose core activities consist of 
processing operations that require regular and systematic monitoring of the data subjects, a person with expert knowledge 
of data protection law and practices should assist the controller or processor to monitor internal compliance with this 

The DPO is similar to a compliance officer and is also expected to be proficient at managing IT processes, data security 
(including dealing with cyberattacks) and other critical business continuity issues around the holding and processing of 
personal and sensitive data. The skill set required stretches beyond understanding legal compliance with data protection 
laws and regulations.

The appointment of a DPO in a large organization will be a challenge for the board as well as for the individual concerned. 
There are myriad governance and human factor issues that organizations and companies will need to address given the 
scope and nature of the appointment. In addition, the DPO must have a support team and will also be responsible for 
continuing professional development to be independent of the organization that employs them, effectively as a 

More details on the function and the role of data protection officer were given on 13 December 2016 (revised 5 April 2017) 
in a guideline document.

The GDPR refers to pseudonymisation as a process that is required when data are stored (as an alternative to the other 
option of complete data anonymization) to transform personal data in such a way that the resulting data cannot be attributed 
to a specific data subject without the use of additional information. An example is encryption, which renders the original data 
unintelligible and the process cannot be reversed without access to the correct decryption key. The GDPR requires for the 
additional information (such as the decryption key) to be kept separately from the pseudonymised data.

Another example of pseudonymisation is tokenization, which is a non-mathematical approach to protecting data at rest 
hat replaces sensitive data with non-sensitive substitutes, referred to as tokens. The tokens have no extrinsic or exploitable 
meaning or value. Tokenization does not alter the type or length of data, which means it can be processed by legacy systems 
such as databases that may be sensitive to data length and type.

That requires much fewer computational resources to process and less storage space in databases than traditionally-encrypted 
data. That is achieved by keeping specific data fully or partially visible for processing and analytics while sensitive information 
is kept hidden.
Pseudonymisation is recommended to reduce the risks to the concerned data subjects and also to help controllers and 
processors to meet their data protection obligations (Recital 28). The GDPR encourages the use of pseudonymisation to 
"reduce risks to the data subjects" (Recital 28).

Right of access
The right of access (Article 15) is a data subject right. It gives citizens the right to access their personal data and information 
about how this personal data is being processed. A data controller must provide, upon request, an overview of the categories 
of data that are being processed (Article 15(1)(b)) as well as a copy of the actual data (Article 15(3)). Furthermore, the data 
controller has to inform the data subject on details about the processing, such as the purposes of the processing (Article 15(1)(a)), 
with whom the data is shared (Article 15(1)(c)), and how it acquired the data (Article 15(1)(g)).

Right to erasure
right to be forgotten was replaced by a more limited right of erasure in the version of the GDPR that was adopted by the 
European Parliament in March 2014.  Article 17 provides that the data subject has the right to request erasure of personal 
data related to them on any one of a number of grounds, including noncompliance with Article 6(1) (lawfulness) that includes a 
case (f) if the legitimate interests of the controller is overridden by the interests or fundamental rights and freedoms of the data 
subject, which require protection of personal data see also: 

Data portability
Further information: Data portability
A person is to be able to transfer personal data from one electronic processing system to and into another, without being 
prevented from doing so by the data controller. Data that has been sufficiently anonymised is excluded, but data that has 
been only de-identified but remains possible to link to the individual in question, such as by providing the relevant identifier, 
is not. Both data being 'provided' by the data subject and data being 'observed', such as about behaviour, are included. 
In addition, the data must be provided by the controller in a structured and commonly used standard electronic format. 
The right to data portability is provided by Article 20 of the GDPR.Legal experts see in the final version of this measure 
a "new right" created that "reaches beyond the scope of data portability between two controllers as stipulated
 in [Article 20]".

Data protection by design and by default
Data protection by design and by default (Article 25) requires data protection to be designed into the development of 
usiness processes for products and services. Privacy settings must therefore be set at a high level by default, and technical 
and procedural measures should be taken by the controller to make sure that the processing, throughout the whole processing 
lifecycle, complies with the regulation. Controllers should also implement mechanisms to ensure that personal data is not 
processed unless necessary for each specific purpose.

A report by the European Union Agency for Network and Information Security elaborates on what needs to be done to achieve 
privacy and data protection by default. It specifies that encryption and decryption operations must be carried out locally, not by 
remote service, because both keys and data must remain in the power of the data owner if any privacy is to be achieved. 
The report specifies that outsourced data storage on remote clouds is practical and relatively safe if only the data owner, 
not the cloud service, holds the decryption keys.

Records of processing activities
Records of processing activities must be maintained that include purposes of the processing, categories involved and envisaged 
time limits. The records must be made available to the supervisory authority on request (Article 30).

Nota Bene: 
Helsinki Think Tank is excluded due to following legal restrictions

The following cases are not covered by the regulation:
  • Lawful interception, national security, the army, the police, justice
  • Statistical and scientific analysis
  • Deceased persons are subject to national legislation
  • There is a dedicated law on employer-employee relationships
  • Processing of personal data by a natural person in the course of a purely personal or household activity

Legal disclaimer
Helsinki Think Tank is protected by The General Data Protection Regulation (GDPR) (EU)

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