CVM Chemie-Vertrieb Magdeburg GmbH & Co. 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?
   To provide telecommunications systems for our own purposes (internal and external corporate communications), e.g. telephone systems, video calls, CTI, fax servers, voice servers and answering machines. To ensure the proper functioning of internal and external telecommunications. To provide log data, analyses and statistics.
    
2. Who is the data controller for this processing?
   CVM Chemie-Vertrieb Magdeburg GmbH & Co. KG
   Address: Werner-von-Siemens-Ring 8, 39116 Magdeburg
   Telephone: +49 (0) 391 / 50 86 20 - 0
   Fax: + 49 (0) 391 / 50 86 20 - 40
   Website: www.cvh.de
   Email: magdeburg@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 in accordance with Article 6(1)(f) of the GDPR
    
5. Specifically, which ‘legitimate interests’ is the controller pursuing?
   Generally necessary measures relating to the organisation
     of the business

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

   • No disclosure of traffic data!  
   • External service providers / support staff / technicians  
   • Management  
   • IT department  
   • IT service providers  

    

7. When is the data deleted? 

   • 6 months for connection and traffic data  
   • 10 years for telephone cost statements, if there are booking documents  
   • 6 years for telephone cost statements where no accounting documents exist  
   • As a general rule, we delete personal data once there is no longer any need to retain it. Such a need may arise, in particular, where the data is still required to fulfil contractual obligations, or to assess, grant or contest warranty and, where applicable, guarantee claims. In the case of statutory retention obligations, deletion may only be considered once the relevant retention period has expired.  

    

8. What categories of data are processed? 

   • Connection and usage data (IP addresses, telephone numbers, metadata (time, duration of connection, telephone numbers))
   • Meta/communication data (device IDs, IP addresses)
   • Itemised billing records
   • Log data (of a technical nature)

    

9. Which individuals are affected? 

   • Users of the company’s telecommunications systems (internal: employees
   • External: callers)

    

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 in this regard.
     
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, where applicable, withdrawn your consent 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 the purposes of establishing, exercising or defending 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. We will then assess whether we have compelling legitimate grounds for the processing.
     
15. The right to “withdraw consent”
    You have the right to withdraw your consent (where this is relevant to the processing described here). The withdrawal applies only with future effect.
     
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 Saxony-Anhalt, Leiterstr. 9, 39104 Magdeburg, GERMANY, Tel. 0049 391-81803-0, www.datenschutz-sachsen-anhalt.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.
     
19. Does profiling take place? Are personal characteristics analysed or predicted? Does automated individual decision-making take place?
    No, this does not take place.
     
20. Are data transferred to recipients in third countries (i.e. outside the EU)?
    No, this does not take place.
     
21. Are there multiple 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 that demand what could be considered an exhaustive range of details. In some cases, the information requested 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 data CATEGORIES.
   
• 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 may, in accordance with Article 30(1g), 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 shall only specify the CATEGORIES of recipients and not any 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 us and our customers that might arise should it become public knowledge. 

Blanket requests for erasure/restriction or blanket withdrawals of consent/objections etc. are problematic. Please put yourself in our position: are we expected to alter our data processing 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 fulfilling these data subject rights under Articles 15–21. Please contact us in this regard.