Introduction
This document describes the framework and procedures for data handling adopted by TRB Global Market LLC, a Wyoming incorporated company. Our approach is designed to meet the requirements of data protection laws—including the GDPR—and outlines the measures we take to securely collect, process, and store data across our decentralized team.
Data Protection Principles
TRB Global Market LLC operates under a set of core principles to ensure data security:
- Legality, Fairness, and Transparency: We process data in a manner that complies with legal standards, is fair, and is conducted transparently.
- Purpose Limitation: Data is collected exclusively for well-defined, legitimate purposes and is not used beyond those objectives.
- Data Minimization: Only the minimum data necessary for our operations is gathered.
- Accuracy: We maintain data that is accurate and updated regularly.
- Storage Duration: Information is retained only for as long as it is needed to fulfill its purpose.
- Security and Confidentiality: Robust safeguards are implemented to prevent unauthorized access, alteration, or loss.
Roles and Responsibilities
- Data Controller: TRB Global Market LLC defines the purposes and methods for processing data.
- Data Processors: We collaborate with third-party service providers (such as cloud storage or communication tools) for specific processing tasks.
- Data Protection Officer (DPO): An assigned officer oversees our adherence to data protection regulations and serves as the main point of contact for data subjects and authorities.
Data Categories and Purposes
- Client Information: Includes contact details, contractual records, payment information, and project requirements.
- Employee Information: Encompasses personal data, payroll records, and performance metrics required for HR functions.
- Candidate Information: Covers resumes, interview notes, and assessment outcomes used in recruitment.
- Operational Data: Consists of information essential for daily business activities, including internal communications and collaboration.
Data Processing Protocols
5.1. Collection
- Data is gathered via secure online forms, formal agreements, and validated communication channels.
- Appropriate consent is obtained wherever required by law.
5.2. Storage
- Data is stored on encrypted cloud platforms (e.g., Google Workspace, Notion, HubSpot) with access restricted to authorized users.
5.3. Access Control
- Access is granted based on user roles, ensuring that employees see only the data necessary for their tasks.
- Multi-factor authentication (MFA) is enforced across all accounts.
5.4. Transmission
- Data is transmitted over secure channels utilizing TLS encryption.
5.5. Retention and Deletion
- Retention schedules are established based on both legal and operational criteria.
- Data is securely erased or anonymized once it is no longer required.
Security Measures
6.1. Technical Measures
- Encryption: We implement AES-256 encryption for data at rest and TLS for data in transit.
- Backup Systems: Daily automated backups are maintained in secure environments.
- Endpoint Protection: All employee devices are protected by antivirus software, firewalls, and VPNs.
6.2. Organizational Measures
- Remote Work Policies: Guidelines ensure secure remote work practices, including strict password and device usage protocols.
- Incident Response: Established procedures allow for swift action in case of a data breach.
- Training: Regular cybersecurity and data protection training is provided to all personnel.
Vendor and Sub-Processor Management
- Vendor Due Diligence: All partners are thoroughly evaluated for compliance with our data protection standards.
- Data Processing Agreements (DPAs): We formalize DPAs with all vendors to guarantee secure handling of data.
- Sub-Processor Transparency: A publicly accessible and regularly updated list of all sub-processors is maintained.
Data Subject Rights
TRB Global Market LLC ensures that individuals can exercise their rights—including access, rectification, erasure, data portability, and the right to restrict or object to processing—with all requests processed within 30 days.
International Data Transfers
- Standard Contractual Clauses (SCCs): We use SCCs to govern any data transfers outside the EEA.
- Supplementary Measures: Additional security measures, including enhanced encryption, are applied to protect international data transfers.
Monitoring and Auditing
Regular internal audits are carried out to ensure adherence to this framework, and external audits may be conducted annually to verify our compliance with data protection regulations.
Updates and Review
This data processing plan is reviewed on an annual basis—or more frequently if required by changes in legislation, business practices, or technological advancements.