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Exemplar draft text for the Table of Contents headings above selected and marked as *
Note: the test in square brackets [..] indicate a principle or objective that the statement seeks to address.
Data Protection
The RP/Service Provider agrees and warrants:
- [Legal compliance] to only process the Attributes in accordance with the relevant provisions of the law applicable to the RP/Service Provider/Federation;
- [Purpose limitation] to only process Attributes of the End User that are necessary for enabling access to the service provided by the Service Provider;
- [Data minimisation] to minimise the Attributes requested from a party to the Federation to those that are adequate, relevant and not excessive for enabling access to the service and, where a number of Attributes could be used to provide access to the service, to use the least intrusive Attributes possible;
- [Deviating purposes] not to process the Attributes for any other purpose (e.g. selling the Attributes or selling the personalisation such as search history, commercial communications, profiling) than enabling access, unless prior consent has been given to the Service Provider by the End User;
- [Data retention] to delete or anonymise all Attributes as soon as they are no longer necessary for the purposes of providing the service;
- [Third parties] not to transfer Attributes to any third party (such as a collaboration partner) except 1. if mandated by the Service Provider for enabling access to its service on its behalf, or 2. if the third party is committed to the Code of Conduct or has undertaken similar duties considered sufficient under the data protection law applicable to the Service Provider or 3. if prior consent has been given by the End User;
- [Security measures] to take appropriate technical and organisational measures to safeguard Attributes against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access. These measures shall ensure a level of security appropriate to the risks represented by the processing and the nature of the data to be protected, having regard to the state of the art and the cost of their implementation.
- [Information duty towards End User] to provide to the End User, at least at first contact, in an easily, directly and permanently accessible way a Privacy Policy, containing at least the following information:
- the name, address and jurisdiction of the Service Provider;
- the purpose or purposes of the processing of the Attributes;
- a description of the Attributes being processed
- the third party recipients or categories of third party recipient to whom the Attributes might be disclosed, and proposed transfers of Attributes to countries outside of the jurisdiction/federation
- the existence of the rights to access, rectify and delete the Attributes held about the End User;
- the retention period of the Attributes;
- a reference to this Code of Conduct;
- [Information duty towards the Federation party/IDP] to provide to it or its Agent at least the following information:
- machine-readable link to the Privacy Policy;
- indication of commitment to this Code of Conduct;c. any updates or changes in the local data protection legislation, which are less strict than the principles set out in this Code of Conduct;
- [Security Breaches] to, without undue delay, report all suspected privacy or security breaches(including unauthorized disclosure or compromise, actual or possible loss of data, documents or any device, etc.) concerning the Attributes, to the Federation Party/IdP or its Agent;
- [Transfer to third countries] when Attributes are being transferred outside the jurisdiction and to countries with adequate data protection pursuant to adequacy law/rules etc.. to ensure an adequate level of protection of the Personal Data by taking appropriate measures pursuant to the law of the country in which the RP/Service Provider is established, such as requesting End User consent or entering into agreements with the RP/Service Provider.
Admin, Record Keeping and Processes/procedures
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