General Data Protection Regulation (GDPR)

Introduction

The purpose of this article is to provide an introduction to how Antenor BMS complies with The General Data Protection Regulation (GDPR).

1.0 General

Antenor-OTG AS processes certain personal information on behalf of its customers by providing its software. The system will be used to store the information of the controller for the modules that the client has chosen to use. Users are normally registered with name and email as a unique user ID. Name and email can be used by Antenor-OTG AS to send relevant and necessary system information. The customer’s system administrator registers the user name and email and even gives the access they think the end user should have to the different parts of the software. The client responsible for treatment must use their own internal routines for the necessary information for users about the use of personal data in Antenor BMS.

NB! Modules for competence and personal injury may contain sensitive data and the customer must be careful when accessing these modules. Beyond these two modules, only user names are used by the system. Antenor-OTG AS is not responsible for the use of personal data in eg. text fields. This must be regulated by internal routines of the individual customer.

2.0 Time boundary

Registrations are maintained as long as the customer is a user of the software. This is to document the necessary history (ref. Industry standards and legal requirements). Upon termination of the agreement, the customer has the right to extract the data that he / she wants, but can also ask Antenor-OTG AS for assistance. All history is deleted from Antenor-OTG AS’ databases at the earliest within 6 months and no later than 12 months unless otherwise agreed in writing.

3.0 Insight

The customer has full access to the system and access to himself and delete and / or archive documents in the system. Antenor-OTG AS will assist according to standard rates upon request. All assistance must be ordered in writing by the system administrator at the customer

4.0 Segmentation of data

Data is stored in customer-specific databases, which means that one customer’s data is completely independent of and separated from another customer’s data. This ensures that there is no danger of data being mixed between customers or customers affecting / being affected by other customers’ data.

5.0 Antenor employees’ access to system

Antenor-OTG AS employees have full access to the system due to service needs. Employees sign their own declaration of confidentiality and ethical guidelines that outline confidential processing of data in the system.

6.0 Sub-processors and third-party services

Antenor uses selected sub-processors and third-party service providers as part of the delivery of Antenor BMS / ABMS. These providers support infrastructure, communication, network, and backup-related operations and may process personal data on behalf of Antenor.

Current providers include:

Hetzner, used for primary server infrastructure and hosting in Europe, including Nuremberg, Germany.
Relevant information: Datacenter information, Data privacy / DPA information.

Cloudflare, used for DNS, SSL / traffic handling, and related edge/network services.
Relevant information: Cloudflare Customer DPA.

Postmark, used for transactional email delivery.
Relevant information: Data Processing Addendum.

Pusher, used for real-time notifications and related messaging features.
Relevant information: Terms of Service, Privacy Statement, Data Processing Agreement.

Google Drive / Google One, used for secondary backup storage.
Relevant information: Google Privacy & Terms, Google One Help

Antenor-OTG evaluates suppliers based on relevant criteria such as security, availability, support quality, contractual terms, data processing terms, and portability.

7.0 Antenor’s backup routines

The automatic backup routine is configured by employees of Antenor-OTG AS, and runs from 01.07.2018 once per hour, 24/7. Should the system fail to make a backup, Antenor-OTG Support will notify you so that the situation can be dealt with immediately.

All backups are stored in the cloud on servers within the EU.

As of 01.05.2022 we store 7 daily, 4 weekly, 12 monthly and 1 annual backups on the above servers.

Restore from backup can be done either on specific files / folders, or full system. Alternatively, Antenor-OTG AS can download a backup to its local environment. It can then be uploaded to a server for restoration via FTP. This does not cause any downtime for the ABMS system server.

8.0 Acceptance Criteria

The following minimum criteria must be complied with by Antenor-OTG AS’ system suppliers:

Availability: Antenor-OTG AS guarantees 99% uptime.

Maximum response time: 1000 ms within Norway. Expect slightly higher in other parts of the world.

Physical security: Physical servers are expected to be in a locked server room, where only staff with operational needs has access. It is further expected that, if desired, Antenor-OTG AS can obtain a log of who has had access and when, and who has used their access and when.

Data security: It is expected that Antenor-OTG AS’ customers’ data is stored securely, behind a firewall, in a data environment that is well updated with current security routines and processes.

Data recovery: Subcontractors are expected to have good backup routines, or alternatively giving Antenor the opportunity to configure the backup routines. Furthermore, it is expected that subcontractors can assist in running a data restore should this be necessary.

Physical location: Norway

Data access: Only employees of subcontractors who have operational or supportive reasons for access should have access to Antenor-OTG AS’ and customers’ data.

Possibility of data transport: It should be easy to move data from one subcontractor to another, should Antenor want such a switch. All data shall, in relation to subcontractors, be owned by Antenor-OTG AS. Furthermore, copying and deletion of said data needs to be at the discretion of Antenor-OTG AS

Process for identifying problems and solutions: Subcontractors are expected to have a support phone number. Furthermore, subcontractors are expected to have technicians available for identification and problem solving 24/7.

Agreement termination criteria: It is expected that no notice is required earlier than 30 days before any renewal of a subscription.

9.0 Overview module by module – standard available modules

Modul	Type of personal data	Basis for registration	Sensitivity/risk	Accessrigths	Necessary action to reduce access
NCR	Name of sender, processor and verifier	The sender must be notified of the processing of the case. The sender must know the name of who will receive and process the case and it is necessary that you also know who verifies the discrepancy. History must be maintained, including who has contributed with various activities	None	Everyone with access to the company’s NCR module. User access is arranged and controlled by the customer	None
Governing Documents	Name of process owner and who issued the document. Also, who is responsible in a process	Data is necessary to ensure clear responsibilities in a company. History must be preserved, including who has contributed with various activities	None	Everyone with access to the company’s module for governing documents. User access is arranged and controlled by the customer	None	The ISO standard requires that a full history be maintained and that no documents can be deleted.
Risk Management	Participants in the risk process	Secure a history of who has participated in risk analyses, who has carried out measures and who has approved measures	None	Everyone with access to the company’s Risk Management module. User access is arranged and controlled by the customer	Ingen	Risk analyzes and the history t must not be deleted, including who has carried out and approved various measures. Current affairs in accordance with, eg accidents/incidents that require investigation
KPI Scorecard	None		None
Leverandørevaluering	None		None
Audit	Names of participants and interviewees	Secure a log of who has participated in the audit and who has given the necessary answers	None	Everyone with access to the company’s audit management module. User access is arranged and controlled by the customer	None
Customer satisfaction	None		None
Safety inspection	Names of participants on the Safety inspection	Secure a log of who has participated in the safety round	None	Everyone with access to the company’s safety inspection module. User access is arranged and controlled by the customer	None
Equipment Management	Equipment resbonsible	Ensure that the person responsible for equipment is notified and has an overview of what is to be carried out. History must be preserved, including who has contributed with various activities	None	Anyone with access to the company’s module for Eqm. User access is arranged and controlled by the customer	None	History must be taken care of as a result of documentation requirements in fm events
Competense	Name, next of kin, competence status of each individual	• Next of kin information is safeguarded with a view to emergency situations • Personnel competence is safeguarded to ensure that the company has the competence it needs at all times • Personal competence and personal development are measured over time Competence must also be able to be documented and traced back in time	Average	As of January 2018, everyone with access to the module has access to all data. User access, on the other hand, is controlled by the customer.	Measures	The customer can limit access himself, but in order to increase the benefit of the system, additional access levels will be built in that ensure limited access
Process measurements	None		None
Personal injury	None, only data in relation to accidents	The standard form has no personal data, only general data	None	User access is arranged and controlled by the customer
Substance register	None		None
5s	None		None
Job safety Analysis	Name of participants	Logging the participants of JSA	None	Everyone with access to the company’s module for JSA. User access is arranged and controlled by the customer
environmental aspects	None		None
New modules and customer adaptations	Not applicable	In the case of new development and/or configurations of the standard, it must be ensured that personal data is safeguarded.	Average		Mesaures	Update development procedures and configuration procedures that ensure that one processes personal data in accordance with legal requirements.