Technical and Organisational Measures (TOM) within the meaning of Art. 32 GDPR

Information

This document describes the technical and organizational measures taken by PLANTA to guarantee a high level of data protection (TOM document).
The measures are categorized as described in Art. 32 GDPR.

Notes

This document must be updated in the event of changes to the processes or significant changes made to the properties of the tools used.
In order to be able to guarantee that this document is up-to-date, the concrete naming of tools for implementing the individual measures was deliberately omitted. Measures that serve different protective purposes are mentioned several times.

Measures

Information

Measures have been taken to ensure the points described below, depending on the type of personal data or data categories to be protected.

1) Access control

To prevent unauthorized persons from gaining access to data processing systems on which personal data is processed or used:

Alarm system
Automatic access control system
Chip card/transponder locking system
Locking system with code lock
Security locks
Motion detector
Key holder regulation
Careful selection of security personnel or the service provider
Careful selection of cleaning staff (internal)

2) Access control

To prevent unauthorized persons from using data processing systems:

Assignment of user rights
Authentication with user name/password and a second factor
Assignment of user profiles to IT systems
Use of VPN technology
Security locks
Key holder regulation
Careful selection of security personnel or the service provider
Careful selection of cleaning staff (internal)
Use of intrusion detection systems
Use of intrusion prevention systems
Use of anti-virus software
Use of a hardware firewall
Use of a software firewall

3) Access control

To ensure that persons authorized to use a data processing system only have access to the data covered by their access authorisation and that personal data cannot be read, copied, altered or erased by unauthorized persons during processing, use and after storage:

Creation of an authorization concept
Management of rights by a system administrator
The number of administrators is reduced to a "minimum"
Password guidelines
Logging of access to applications, in particular when entering, changing and deleting data
Secure storage of data carriers
physical erasure of data carriers before reuse
Proper destruction of data carriers by service providers (files and removable data storage media according to DIN 32757 level 3)
Documentation of the destruction
Encryption of data carriers

4) Transmission control

To ensure that personal data cannot be read, copied, altered or erased without authorization during their transmission, transport or storage, and that it is possible to verify and establish to which bodies the transmission of personal data is intended via data transmission systems:

Use of VPN technology in some cases with hardware dongle or token
Transfer of data in anonymized or pseudonymized form
Documentation of the duration of the planned transfer or agreed deletion periods

5) Input control

To guarantee that it can be verified and determined retrospectively whether and by whom personal data was entered, altered or erased in data processing systems.

Logging of the input, alteration and deletion of data
Traceability of data input, alteration and deletion through the use of individual user names (not user groups)
Retention of forms from which data has been transferred to automated processing
Assignment of rights for input, alteration and deletion of data based on an authorization concept

To guarantee that personal data is protected against accidental destruction or loss:

Uninterruptible power supply (UPS)
Air conditioning in server rooms
Humidity and temperature sensors with alarm circuit
Devices for the monitoring of temperature and humidity in server rooms
Protective power strips in server rooms
Fire and smoke detection systems
Fire extinguishers in server rooms
Alarm in the case of unauthorized access to server rooms
Backup & recovery concept
Testing of data recovery
Emergency plan with automatic engagement of external security companies and the fire department (e.g. silent alarm)
Storage of data backups at multiple secure, external places
No server rooms under sanitary facilities

1) Instruction control

To ensure that personal data processed on behalf of the client can only be processed in accordance with the client's instructions:

Selection of the contractor under aspects of due diligence (in particular with regard to data security)
Committing the contractor’s employees to comply with data secrecy
Ensuring the erasure of data after completion of the mission
Continuous examination of the contractor and its activities

2) Separation requirement

To guarantee that data collected for different purposes can be processed separately:

Authorization concept
Definition of database rights
Separation of productive and test systems
Separation of individual customer systems