Thank you for your interest in RoundTable Studio’s website. RoundTable Studio S.A. (‘RTS’, ‘we’, ‘us’ or ‘our’) is committed to ensuring the security and protection of the personal information that we process, and to provide a compliant and consistent approach to data protection. We have always had a robust and effective data protection program in place which complies with existing law and abides by the data protection principles. However, we recognize our obligations in updating and expanding this program to meet the demands of the GDPR and Uruguay’s Protection of Personal Data and Habeas Data Action (Law 18,331) (2008) and Decree No. 414/009 Regulating Law 18.331 Relating to the Protection of Personal Data, regulated by the Uruguayan data protection authority (URCDP).
RTS is dedicated to safeguarding the personal information under our remit and in developing a data protection regime that is effective, fit for purpose and demonstrates an understanding of, and appreciation for the new Regulation. Our preparation and objectives for GDPR compliance have been summarized in this statement and include the development and implementation of new data protection roles, policies, procedures, controls and measures to ensure maximum and ongoing compliance.
RTS has a consistent level of data protection and security across the organization, with the aim to maintain compliance with the GDPR at all times through the following steps:
- Information Audits - carrying out regular company-wide information audits to identify and assess what personal information we hold, where it comes from, how and why it is processed and if and to whom it is disclosed.
- Policies Procedures implementation of data protection policies and procedures to meet the requirements and standards of the GDPR and any relevant data protection laws, including: -
- Data Protection – our main policy and procedure document for data protection has been designed to meet the standards and requirements of the GDPR. Accountability and governance measures are in place to ensure that we understand and adequately disseminate and evidence obligations/responsibilities with a dedicated focus on privacy by design and the rights of individuals.
- Data Retention & Erasure –our retention policy and schedule is regularly updated to ensure that we meet ‘data minimization’ and ‘storage limitation’ principles, and that personal information is stored, archived and destroyed compliantly and ethically. We have dedicated erasure procedures in place to meet ‘Right to Erasure’ obligation and are aware of when this and other data subject’s rights apply, along with any exemptions, response timeframes and notification responsibilities.
- Data Breaches – our breach procedures ensure that we have safeguards and measures in place to identify, assess, investigate and report any personal data breach at the earliest possible time. Our procedures are robust and have been disseminated to all employees, making them aware of the reporting lines and steps to follow.
- International Data Transfers & Third-Party Disclosures – for any storage or transfer of personal information, we have robust procedures and safeguarding measures in place to secure, encrypt and maintain the integrity of the data. Our procedures include a continual review of the countries with sufficient adequacy decisions, as well as provisions for binding corporate rules; standard data protection clauses or approved codes of conduct for those countries without. We carry out strict due diligence checks with all recipients of personal data to assess and verify that they have appropriate safeguards in place to protect the information, ensure enforceable data subject rights and have effective legal remedies for data subjects where applicable.
- Subject Access Request (SAR) – we have SAR procedures in place to accommodate the revised 30-day timeframe for providing the requested information and for making this provision free of charge. Our new procedures detail how to verify the data subject, what steps to take for processing an access request, what exemptions apply and a suite of response templates to ensure that communications with data subjects are compliant, consistent and adequate.
- Legal Basis for Processing - we regularly review all processing activities to identify the legal basis for processing, ensuring that each basis is appropriate for the activity it relates to. Where applicable, we also maintain records of our processing activities, ensuring that our obligations under Article 30 of the GDPR and Schedule 1 of the Data Protection Bill are met.
- Privacy Notice/Policy – we have revised our Privacy Notice(s) to comply with the GDPR, ensuring that all individuals whose personal information we process have been informed of why we need it, how it is used, what their rights are, who the information is disclosed to and what safeguarding measures are in place to protect their information.
- Obtaining Consent - we have revised our consent mechanisms for obtaining personal data, ensuring that individuals understand what they are providing, why and how we use it and giving clear, defined ways to consent to us processing their information. We have developed stringent processes for recording consent, making sure that we can evidence an affirmative opt-in, along with time and date records, and an easy to see and access way to withdraw consent at any time.
- Direct Marketing - we have revised the wording and processes for direct marketing, including clear opt-in mechanisms for marketing subscriptions, a clear notice and method for opting out and providing unsubscribe features on all subsequent marketing materials.
- Data Protection Impact Assessments (DPIA) – although we rarely process personal information that is considered high risk, involves large scale processing or includes special category/criminal conviction data, we have developed stringent procedures and assessment templates for carrying out impact assessments that comply fully with the GDPR’s Article 35 requirements. We have implemented documentation processes that record each assessment, allow us to rate the risk posed by the processing activity and implement mitigating measures to reduce the risk posed to the data subject(s).
- Processor Agreements – where we use any third-party to process personal information on our behalf (e. Payroll, Recruitment, Hosting etc.), we have drafted compliant Processor Agreements and due diligence procedures for ensuring that they (as well as we), meet and understand their/our GDPR obligations. These measures include initial and ongoing reviews of the service provided the necessity of the processing activity, the technical and organizational measures in place and compliance with the GDPR.
- Special Categories Data - where we obtain and process any special category information, we do so in complete compliance with the Article 9 requirements and have high-level encryptions and protections on all such data. Special category data is only processed where necessary and is only processed where we have first identified the appropriate Article 9(2) basis or the Data Protection Bill Schedule 1 condition. Where we rely on consent for processing, this is explicit and is verified by a signature, with the right to modify or remove consent being clearly signposted.
Data Subject Rights
In addition to the policies and procedures mentioned above that ensure individuals can enforce their data protection rights, we provide easy to access information via our website of an individual’s right to access any personal information that RTS processes about them and to request information about: -
- What personal data we hold about them
- The purposes of the processing
- The categories of personal data concerned
- The recipients to whom the personal data has been/will be disclosed
- How long we intend to store the personal data for
- If we did not collect the data directly from them, information about the source
- The right to have incomplete or inaccurate data about them corrected or completed and the process for requesting this
- The right to request erasure of personal data (where applicable) or to restrict processing in accordance with data protection laws, as well as to object to any direct marketing from us and to be informed about any automated decision-making that we use
- The right to lodge a complaint or seek judicial remedy and who to contact in such instances
“Personal data” means any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly through the use of such data. Personal data we collect through our website that can be used to specifically identify you, is information such as your:
- Telephone Number
- E-mail Address
- Job Title
- Postal Code
- Cookie identifiers and information contained in cookies
You provide us with this personal data when using the Contact Us Form from the website.
Use of Personal Data
In some sections of this website you have the opportunity to voluntarily provide us with personal data about yourself using an online form, to request information from us, when you apply online for a position at RoundTable Studio or at our other offices and subsidiaries and affiliates, or when you apply to become our partner and send us an email with your personal data.
Cookies are small pieces of information transferred by the website to the hard disk of the user's computer and vice versa that allow the completion of some functions of the website. The Cookies that our website records in the hard disk of the user never contain personal data.
By not accepting cookies, some functions of the Website may be disabled for the user.
Information Security & Technical and Organizational Measures
RTS takes the privacy and security of individuals and their personal information very seriously, and takes every reasonable measure and precaution to protect and secure the personal data that we process. We have robust information security policies and procedures in place to protect personal information from unauthorized access, alteration, disclosure or destruction and have several layers of security measures, including, SSL, access controls, password policies, encryptions, pseudonymization, practices, restrictions, authentications, etc.
GDPR Roles and Employees
RTS IT Team is in charge of Data Protection related matters and we have appointed a data privacy team to ensure compliance with data protection regulations. The team is responsible for promoting awareness of the GDPR across the organization, assessing our GDPR compliance, identifying any gap areas and implementing new policies, procedures and measures.
RTS understands that continuous employee awareness and understanding is vital to continued compliance with Data Protection and the GDPR, and it forms part of our induction and ongoing training programs.
Every website visitor that has provided personal data to RTS is entitled to contact our IT team with any queries about our preparation for Data Protection and the GDPR at the following addresses:
We may change, update or amend this Privacy Note at any time and for any reason. You can review this Privacy Note each time you visit our website.