1. Overview and Purpose

This document establishes the data privacy guidelines, principles, and operational procedures for our systems, including the ECTS infrastructure. We are committed to protecting the confidentiality, integrity, and availability of all personal and sensitive data processed within our environment in compliance with applicable data protection regulations.

2. Core Data Privacy Principles

Our data processing activities adhere to the following core principles:

Lawfulness, Fairness, and Transparency: Data is processed legally, fairly, and in a transparent manner relative to the data subject.

Purpose Limitation: Data is collected for specified, explicit, and legitimate purposes and not further processed in a manner incompatible with those purposes.

Data Minimization: Collection is adequate, relevant, and limited to what is necessary regarding the purposes for which they are processed.

Accuracy: Data is kept accurate and, where necessary, kept up to date.

Storage Limitation: Data is kept in a form which permits identification of data subjects for no longer than is necessary.

Integrity and Confidentiality: Data is processed in a manner that ensures appropriate security, including protection against unauthorized or unlawful processing and accidental loss, destruction, or damage, using appropriate technical and organizational measures.

3. Supporting Policies and Procedures

A. Data Classification and Handling Procedure

Data Inventory: All data processed within the ECTS system must be cataloged, identifying data types, sensitivity levels, and storage locations.

Access Control: Access to personal data is restricted based on the Principle of Least Privilege (PoLP) and role-based access control (RBAC).

B. Incident Response and Data Breach Procedure

Detection & Reporting: Any suspected or confirmed security breach or unauthorized data access must be reported immediately to the security/privacy team.

Containment & Mitigation: Immediate technical steps must be taken to isolate affected components (e.g., revoking compromised API keys, patching vulnerabilities).

Notification: Relevant stakeholders and regulatory authorities are notified within legally mandated timeframes if a breach poses a high risk to data subjects.

C. Data Retention

Retention Schedules: Data is retained only as long as necessary to fulfill the operational purpose or comply with statutory retention requirements.

4. Technical and Organizational Security Measures

Encryption: Data in transit is protected using strong cryptographic protocols and sensitive data at rest is encrypted.

Logging and Auditing: System activities, administrative access, and data modifications are logged to ensure traceability and auditability.

API Security: Third-party integrations (such as external APIs and server components) undergo security reviews to ensure they meet privacy standards.