GDPR FREQUENTLY ASKED QUESTIONS
1. What is the current status of Food Handler Solutions LLC’s GDPR compliance?
Food Handler Solutions LLC intends and expects to comply with GDPR by its effective date on 25 May 2018, including having a legal basis under Article 6 GDPR for processing any personal data.
2. How do Food Handler Solutions LLC Software as Service products process personal data?
Minimally, if at all. Food Handler Solutions LLC has two Software as a Service (SaaS) offerings: Food Handler Solutions LLC Pro and Food Handler Solutions LLC Local. Food Handler Solutions LLC Pro is a Food Handlers License “state of the art” food safety education and certificate programs SaaS product that helps subscribers analyze the effectiveness of keywords and other aspects of their online properties to enhance searchability and ranking.
Food Handler Solutions LLC Local is a SaaS product that provides subscribers a more efficient means of managing, updating, and maintaining the online basic business name, address, and location data about their physical business locations, whether on their own online properties or with a variety of business listing websites. While in limited circumstances it can be argued that the business listing data Food Handler Solutions LLC Local processes could be personal data as well, the subscriber is using Food Handler Solutions LLC in order to make this information available online and to the public, suggesting a very low interest in exercising the protective rights GDPR affords data subjects in their respective personal data. Moreover, the subscriber controls the use of any business listing information in Food Handler Solutions LLC Local through a user dashboard.
3. Is sensitive data stored within Food Handler Solutions LLC tools?
Food Handler Solutions LLC does not currently believe that it processes, let alone seeks or expect that it will seek to process, any personal data that is subject to Article 9 GDPR, “Processing of special categories of personal data,” which, in reference to GDPR, is generally referred to as “sensitive personal data.”
4. Are you a data processor, as you store and organize data from other sources?
Food Handler Solutions LLC currently does not believe it is a data processor for a data controller, necessitating that it enter into customary and compliant data processing agreements with data controllers. However, should that change, in order to comply with GDPR, Food Handler Solutions LLC believes that both Food Handler Solutions LLC as a data processor and the data controller will need to enter into a compliant data processor agreement.
5. Is Food Handler Solutions LLC able or will Food Handler Solutions LLC be able to respond to data subject requests under GDPR?
6. In particular, if I am a data subject and Food Handler Solutions LLC is a data controller to my personal data, can Food Handler Solutions LLC comply with my request “to be forgotten”?
Yes. However, a data subject should understand the consequences of such a request.
For example, with respect to any personal data that provides the necessary contact details in order to administer a subscription for a subscriber that is an organization, Food Handler Solutions LLC will need to replace the contact information within its system in order to manage the subscriber’s subscription and account.
For any subscribers who are individuals, complying with a request to be forgotten will, of course, cause a permanent termination of the subscriber’s account and subscription. Food Handler Solutions LLC also often tries to “win-back” terminated or expired subscribers with discount offers, and eliminating or permanently “forgetting” personal data will eliminate Food Handler Solutions LLC’s ability to make any such offers to the data subject.
If you are a data subject and have requests of Food Handler Solutions LLC under GDPR related to your individual rights in your personal data, including a “request to be forgotten/for erasure,” “rectification,” etc., please email email@example.com and Food Handler Solutions LLC will promptly review your request and respond to you.
7. Which personal data does your company collect?
Most of the personal data that Food Handler Solutions LLC collects occurs in the user or subscriber account creation process, the payment and administration process, as well as the customer care and success processes. That typical data consists of a subscriber or account-holder contact email address; display name; and data required to make a purchase, such as credit card details and billing information, including cardholder first and last name and billing address.
Food Handler Solutions LLC also holds a conference event annually regarding digital marketing and Food Handlers License “state of the art” food safety education and certificate programs called “Food Handler Solutions LLC.” Food Handler Solutions LLC has subscribed to two event registration Software as a Service provider to register attendees and provide payment processing and currently subscribes to the service of just one of those providers. These providers likely collect and process Food Handler Solutions LLC attendee personal data.
Food Handler Solutions LLC does not collect or process any sensitive personal data.
Food Handler Solutions LLC’s efforts to identify all existing and any new sources of personal data collection are ongoing toward being compliant with GDPR by 25 May 2018.
8. Where is the headquarters of your company?
Food Handler Solutions LLC is headquartered at:
Food Handler Solutions LLC
5111 W. Tangerine Rd
Marana, AZ 85658
10. Are you offering data storage and all processing for your EU customers to take place within the EU?
As Food Handler Solutions LLC is headquartered in the United States and is not “established” anywhere in the EU, it does not see any advantage in hosting personal data in the EU, since Food Handler Solutions LLC will have no personnel in the EU to process any of the personal data in order to perform its obligations to its subscribers.
11. Are you willing to sign the mandatory data processing agreement?
As answered in Question 4 (above), Food Handler Solutions LLC currently does not believe it is a data processor for a data controller, necessitating that it enter into customary and compliant data processing agreements with data controllers. However, should that change, in order to comply with GDPR, Food Handler Solutions LLC believes that both Food Handler Solutions LLC as a data processor and the data controller will need to enter into a compliant data processor agreement.
Updated May 31, 2018
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