CVH Chemie-Vertrieb GmbH & Co. Hannover KG

Below, we provide you with detailed information on all the key aspects of this data processing. We refer to all the information requirements arising from Articles 13, 14, 15, 26 and 30 of the GDPR.
 

1. What is the purpose of this processing?
   Communication for business purposes using Office software and an email server. This includes, for example, the ‘Email’, ‘Address Book’, ‘Tasks’, ‘Calendar’ and ‘Notes’ modules.
    
2. Who is responsible for this processing?
   CVH Chemie-Vertrieb GmbH & Co. Hannover KG
   Address: Podbielskistraße 22, 30163 Hannover
   Telephone: +49 (0) 511 / 9 65 35 - 0
   Fax: +49 (0) 511 / 9 65 35 - 240
   Website: www.cvh.de
   Email: hannover@cvh.de
    
3. Who has been appointed as the company’s data protection officer?
   Martin Lorenz, Am Hang 8, 31655 Stadthagen, datenschutzbeauftragter.cvhgruppe[at]triades-datenschutz.de
    
4. What is the legal basis? Why is this processing permitted?
   Protection of the controller’s legitimate interests pursuant to Article 6(1)(f) of the GDPR
    
5. Specifically, which ‘legitimate interests’ is the controller pursuing?
   Measures generally necessary for the organisation
     of the business

6. Who are the authorised recipients (both internal and external)? 

   • Employees
   • Management
   • IT service providers 

    

7. When will the data be deleted? 

   • Tax-related data is retained for ten years in accordance with Section 147(3) of the German Fiscal Code (AO), commencing at the end of the calendar year in which the document was created
   • Commercial correspondence, in accordance with Section 257 of the German Commercial Code (HGB), is retained for six years, starting from the end of the calendar year in which the document was created
   • 6 months – applications following the closure of the job vacancy
   • 2 years – job applications following the closure of the vacancy, with the applicant’s consent
   • All other data for three years in accordance with Section 195 of the German Civil Code (BGB), commencing at the end of the calendar year in which the data was collected
   • As a general rule: data is deleted once the purpose no longer applies and retention obligations have expired 

    

8. What categories of data are processed? 

   • Personal data required to complete the processing operation
   • Master data (names, addresses)
   • Application data
   • Email (date, recipient, text, attachments)
   • Calendar data
   • Meta/communication data (device IDs, IP addresses)

    

9. Which individuals are affected? 

   • Management
   • Public authorities
   • Employees
   • Service providers
   • Email users
   • Customers
   • Prospective customers
   • Suppliers

    

10. The right to ‘access’
    You have the right to access the data relating to you. This document largely ensures that this right is upheld. If you have any further questions or concerns, please do not hesitate to contact us.
     
11. The right to “rectification” of inaccurate data
    You generally have the right to have inaccurate data rectified. Please contact us regarding this.
     
12. The right to “erasure of your data”
    You have the right to have your data erased provided that (a) the data is no longer necessary, (b) you have withdrawn your consent where applicable or there is no other legal basis (any longer), (c) you have lawfully objected, (d) the data has been processed unlawfully, (e) erasure is required by law, (f) the data relates to children and is to be erased. Please note that, in accordance with Article 17(3) of the GDPR, it may not be possible or permissible to erase the data.
     
13. The right to ‘restriction of processing’
    You have the right to have your data ‘restricted’, provided that (a) you contest the accuracy of the data, (b) the processing is unlawful and you do not wish the data to be erased, (c) we no longer require the data, but you still require it for your own legal claims, (d) you have objected to the processing and it has not yet been determined whether the legitimate interests of the controller override yours.
     
14. The right to “object to processing”
    You have the right to object to processing, provided there are grounds relating to your SPECIFIC SITUATION. For our part, we will assess whether we have compelling legitimate grounds for processing.
     
15. The right to “withdraw consent”
    You have the right to withdraw your consent (insofar as this is relevant to the processing described here). The withdrawal applies only to future processing.
     
16. The right to “data portability”
    You have the right to receive a copy of your data (“data portability”), provided that (a) the legal basis is consent or a contract, and (b) you have provided this data yourself, and (c) the data is processed by automated means. Provided these conditions are met, you may also request that we transfer the data to a recipient of your choice.
     
17. The right to “lodge a complaint”
    You have the right to lodge a complaint with any data protection supervisory authority. The contact details of the data protection supervisory authority responsible for us are: LDI Niedersachsen, Prinzenstr. 5, 30159 Hannover Telephone: 0049 511 120 45 00, www.lfd.niedersachsen.de.
    You are welcome to contact us first before getting in touch with the supervisory authority; our highly competent in-house data protection officer will deal with your enquiry much more quickly and just as thoroughly. If we are unable to assist you, you can always contact the supervisory authority afterwards.
     
18. Data collection by third
    parties No, no data is collected by third parties. All data is therefore requested and collected by us directly.
     
19. Does profiling take place? Are personal characteristics analysed or predicted? Is automated individual decision-making carried out?
    No, this does not take place.
     
20. Are data transfers made to recipients in third countries (i.e. outside the EU)?
    USA (An EU Standard Contractual Clause has been concluded. See Article 46(2)(c) of the GDPR.) 
     
21. Are there several data controllers in the sense of ‘joint controllership’?
    No, there is only the ONE data controller mentioned above.
     

Additional information

There are letter templates circulating on the internet for requests for information which demand the most comprehensive information conceivable. In some cases, they request information that goes far beyond what is legally required. We would like to briefly explain this:

• With regard to specific data details (such as first name, surname, telephone number, etc.), there is no obligation to provide such information under the relevant Articles 14(1d), 15(1b) and 30(1c). Accordingly, we are providing you – as requested – with the CATEGORIES of data.
   
• There is also no right to information regarding technical and organisational measures. We do not disclose these measures because doing so would play into the hands of potential attackers. Only the supervisory authority is permitted, under Article 30(1g), to request a general description of these measures. Please rest assured that we take appropriate measures.
   
• With regard to a list of all third parties and data processors, we only specify the CATEGORIES of recipients and do not provide specific company names. This is a permissible option under Articles 13(1e), 14(1e) 15(1c) and 30(1d). We regard the list of our (very carefully selected) suppliers as a trade and business secret and wish to avoid any risks to ourselves and our customers that might arise should it become public knowledge. 

Blanket requests for erasure/restriction or blanket withdrawals/objections etc. are problematic. Please put yourself in our position: are we expected to change our data processing practices without reliable proof of identity? This could lead to serious problems and may even constitute a data protection breach. We will therefore, as a general rule, request additional information in accordance with Article 12(6) before we comply with these data subject rights under Articles 15–21. Please contact us in this regard.