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Personal data processing policy | Editorial archive No. 1

1. General provisions.
1.1. This Personal Data Processing Policy (hereinafter referred to as the PD Processing Policy) IP Nekrasov V.V. (hereinafter referred to as the Operator), OGRNIP 317715400000700, located at the address: Moscow, Presnenskaya embankment, 12, of. 4106 was developed in accordance with the Constitution of the Russian Federation, the Labor Code of the Russian Federation, the Civil Code of the Russian Federation, Federal Law of July 27, 2006 No. 149-FZ “On Information, Information Technologies and Information Protection”, Federal Law of July 27, 2006 No. 152-FZ “On Personal Data”, Decree of the Government of the Russian Federation dated 01.11.2012 No. 1119 “On approval of requirements for the protection of personal data during their processing in personal data information systems”, other federal laws and regulations.
1.2. The policy was developed taking into account the requirements of the Constitution of the Russian Federation, legislative and other regulatory legal acts of the Russian Federation in the field of personal data.
1.3. The PD processing policy has been developed to ensure the protection of the rights and freedoms of the personal data subject when processing his personal data (hereinafter referred to as PD).
1.4. The provisions of the Policy serve as the basis for the development of local regulations regulating the IP Nekrasov V.V. Issues of processing personal data of employees of IP Nekrasov V.V. and other subjects of personal data.

2. Purposes of processing personal data.
Personal data is processed by the Operator for the following purposes:

1) implementation and fulfillment of the functions, powers and responsibilities assigned by the legislation of the Russian Federation to the Operator, in particular:
— compliance with legal requirements in the field of labor and taxation;
— maintaining current accounting and tax records, formation, production and timely submission of accounting, tax and statistical reporting;
— compliance with legal requirements to determine the procedure for processing and protecting personal data of citizens who are clients or contractors of individual entrepreneur V.V. Nekrasov. (hereinafter referred to as subjects of personal data).

2) exercise of the rights and legitimate interests of individual entrepreneur V.V. Nekrasov. within the framework of carrying out the types of activities provided for by the Charter and other local regulations of IP Nekrasov V.V., or third parties or achieving socially significant goals;

3) for other legal purposes.

3. Legal basis for processing personal data.
PD processing is carried out on the basis of the following federal laws and regulations:
1) the Constitution of the Russian Federation;
2) Labor Code of the Russian Federation;
3) Federal Law of July 27, 2006 No. 152-FZ “On Personal Data”;
4) Federal Law “On Information, Information Technologies and Information Protection” dated July 27, 2006 N 149-FZ.
5) Provisions on the specifics of processing personal data carried out without the use of automation tools. Approved by Decree of the Government of the Russian Federation of September 15, 2008 No. 687.
6) Resolution No. 1119 of November 1, 2012 on approval of requirements for the protection of personal data during their processing in personal data information systems.
7) Order of the FSTEC of Russia No. 55, FSB of Russia No. 86, Ministry of Information and Communications of Russia No. 20 dated February 13, 2008 “On approval of the Procedure for classifying personal data information systems”;
8) Order of the FSTEC of Russia dated February 18, 2013 No. 21 “On approval of the composition and content of organizational and technical measures to ensure the security of personal data during their processing in personal data information systems”;
9) Order of Roskomnadzor dated September 5, 2013 No. 996 “On approval of requirements and methods for anonymization of personal data”;
10) Order of the Federal Tax Service dated November 17, 2010 No. MMV-7-3/611, approving the individual income information form, completion guidance, electronic reporting format, and reference directories.
11) Other regulatory legal acts of the Russian Federation and regulatory documents of authorized government bodies.

4. List of actions with personal data.
When processing PD, the Operator will carry out the following actions with PD: collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.

5. Composition of personal data processed.
5.1. The following PD subjects are subject to processing by the Operator: - employees of the Operator; - clients of the Operator; - counterparties of the Operator; - individuals who contact the Operator in the manner established by the Federal Law “On the procedure for considering applications from citizens of the Russian Federation”.
5.2. The composition of personal data for each of the categories of subjects listed in clause 5.1 of these Regulations is determined in accordance with the regulatory documents listed in section 3 of these Regulations, as well as the regulatory documents of the Institution issued to ensure their implementation.
5.3. In cases provided for by current legislation, the subject of personal data decides to provide his personal data to the Operator and consents to their processing freely, of his own free will and in his own interest.
5.4. The operator ensures that the content and volume of processed personal data corresponds to the stated purposes of processing and, if necessary, takes measures to eliminate their redundancy in relation to the stated purposes of processing.
5.5. Processing of special categories of personal data relating to race, nationality, political views, religious or philosophical beliefs, intimate life, in IP Nekrasov V.V. is not implemented.

6. Processing of personal data.
6.1. Processing of personal data in IP Nekrasov V.V. carried out in the following ways:• non-automated processing of personal data;• automated processing of personal data with or without transfer of received information via information and telecommunication networks;• mixed processing of personal data.

7. Ensuring the protection of personal data when processed by the Operator.
7.1 The operator takes measures necessary and sufficient to ensure the fulfillment of the obligations provided for by the Federal Law of July 27, 2006 No. 152-FZ “On Personal Data” and the regulatory legal acts adopted in accordance with it. The operator independently determines the composition and list of measures necessary and sufficient to ensure the fulfillment of the obligations provided for by the Federal Law of July 27, 2006 No. 152 “On Personal Data”, Government Decree of September 15, 2008 No. 687 “On approval of the Regulations on the peculiarities of processing personal data carried out without the use of automation means”, Government Decree of November 1, 2012 No. 1119 “On approval requirements for the protection of personal data during their processing in personal data information systems", order of the FSTEC dated February 18, 2013 No. 21 "On approval of the composition and content of organizational and technical measures to ensure the security of personal data during their processing in personal data information systems", and other regulatory legal acts, unless otherwise provided by federal laws. Such measures include: – appointment by the Operator of a person responsible for organizing the processing of personal data; – publication by the Operator of documents defining the operator’s policy regarding the processing of personal data, local acts on the processing of personal data, as well as local acts establishing procedures aimed at preventing and identifying violations of the legislation of the Russian Federation, eliminating the consequences of such violations; – application of legal, organizational and technical measures to ensure the security of personal data; – implementation of internal control and (or) audit of the compliance of personal data processing with the Federal Law “On Personal Data” and the regulatory legal acts adopted in accordance with it, requirements for the protection of personal data, the Operator’s policy regarding the processing of personal data, local acts of the Operator; – determination of an assessment of the harm that may be caused to personal data subjects in the event of a violation of the Federal Law “On Personal Data”, the ratio of said harm and measures taken by the operator aimed at ensuring the fulfillment of the obligations provided for by the Federal Law “On Personal Data”; – familiarization of the Operator's employees directly involved in the processing of personal data with the provisions of the legislation of the Russian Federation on personal data, including requirements for the protection of personal data, documents defining the Operator's policy regarding the processing of personal data, local regulations on the processing of personal data, and (or) training of these employees.
7.2. When processing personal data, the operator takes the necessary legal, organizational and technical measures or ensures their adoption to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, distribution of personal data, as well as from other unlawful actions in relation to personal data.

8. The right of the subject of personal data to access his personal data.
8.1. The PD subject has the right to demand from the Operator clarification of his personal data, blocking or destruction of it if the personal data is incomplete, outdated, inaccurate, illegally obtained or is not necessary for the stated purpose of processing, as well as take measures provided by law to protect his rights.
8.2. Information is provided to the subject of personal data or his representative by the operator upon contact or upon receipt of a request from the subject of personal data or his representative. The request must contain the number of the main document identifying the subject of personal data or his representative, information about the date of issue of the specified document and the issuing authority, information confirming the participation of the subject of personal data in relations with the Operator (agreement number, date of conclusion of the contract, symbolic verbal designation and (or) other information), or information otherwise confirming the fact of processing of personal data by the Operator, the signature of the subject of personal data or his representative. The request can be sent in the form of an electronic document and signed with an electronic signature in accordance with the legislation of the Russian Federation.
8.3. The operator has the right to refuse the personal data subject to make a repeated request. Such refusal must be motivated. The obligation to provide evidence of the validity of the refusal to execute a repeated request lies with the Operator.
8.4. The subject of personal data has the right to receive information regarding the processing of his personal data, including containing: – confirmation of the fact of processing of personal data by the Operator; – legal grounds and purposes of processing personal data; – purposes and methods of processing personal data used by the Operator; – name and location of the Operator, information about persons (except for the operator’s employees) who have access to personal data or to whom personal data may be disclosed on the basis of an agreement with the operator or on the basis of a federal law;– the processed personal data related to the relevant subject of personal data, the source of their receipt, unless a different procedure for presenting such data is provided for by federal law;– the terms of processing of personal data, including the periods of their storage;– the procedure for the exercise by the subject of personal data of the rights provided for by the Federal Law “On Personal Data”;– information about the completed or intended cross-border transfer of data;– the name or surname, first name, patronymic and address of the person processing personal data on behalf of The operator, if the processing has been or will be entrusted to such a person.
8.5. If the subject of personal data believes that the operator is processing his personal data in violation of the requirements of the Federal Law “On Personal Data” or otherwise violates his rights and freedoms, the subject of personal data has the right to appeal the actions or inaction of the operator to the body authorized to protect the rights of personal data subjects, or in court.
8.6. The subject of personal data has the right to protect his rights and legitimate interests, including compensation for losses and (or) compensation for moral damage in court.