POLICY of the processing of personal data

1. General provision

1.1. The current Policy of the processing of personal data (further – Policy of the processing of PD), LLC “MANUFACTURING COMPANY PROPLAST” (further – Operator), TIN 7720400968, located at the address: Moscow, Kuskovskaya Street, House 27-2-15, is developed in accordance with the Constitution of the Russian Federation, Civil Code of the Russian Federation, Federal law dated 27 July 2006 № 149-FL "About information, information technologies and data protection", Federal law dated 27 July 2006 № 152-FL "On Personal Data", RF Government Regulation dated 01 November 2012 № 1119 "About affirmation of the security requirements to the personal records at its processing in the informational systems of the personal data", other federal laws and statutory and regulatory enactments.
1.2. The policy is prepared taking into account the demands of the Constitution of the Russian Federation, legal acts and other statutory and regulatory enactments of the Russian Federation in the sphere of the personal data.
1.3. The policy of the processing of PD is developed with the objective of ensuring the protection of rights and liberties of the personal data owner at the processing of his personal data (further - PD).
1.4. The regulations of the Policy serve as a basis for the local normative acts development regulating in LLC "PRODUCTION COMPANY PROPLAST" questions of the processing of personal data of the workers of LLC "PRODUCTION COMPANY PROPLAST" and other personal data owners.

2. Purposes of the processing of personal data

Personal data is processed by the Operator for the following purposes:
1) the performing and execution of functions charged by the laws of the Russian Federation on the Operator, competences and obligations including:

  • the execution of the legislation enforcement in the area of work and taxation;
  • the maintenance of the current accounting and tax records, forming, production and accounting, tax and statistical reporting delivery on-time;
  • the legislation enforcement for determination of the handling procedure and protection of the PD of the citizens who are clients or counterparties of LLC "PRODUCTION COMPANY PROPLAST" (further - personal data owners).

2) execution of rights and legal interest of LLC "PRODUCTION COMPANY PROPLAST" under the realization of the activity categories provided by the Articles of the Agreement and other local normative acts of LLC "PRODUCTION COMPANY PROPLAST", or third persons or the achievement of the significant purposes for the society;
3) in other legitimate objectives.

3. Legal foundation of the processing of personal data

The processing of the PD is performed based on the following Federal laws and statutory and regulatory enactments:
1) the Constitution of the Russian Federation;
2) the Labour Code of the Russian Federation;
3) the Federal law dated 27 July 2006 № 152-FL "On Personal Data";
4) the Federal law dated 27 July 2006 № 149-FL "About information, information technologies and data protection".
5) The regulations about the particularities of the processing of personal data performed without the use of the automation facilities.
It is confirmed by the Decree of the Government of the Russian Federation dated 15 September 2008 № 687.
6) Decrees dated 1 November 2012 № 1119 about the affirmation of the security requirements of the personal records at its processing in the informational systems of the personal data.
7) the order of the FSTEC of Russia № 55, Russian Federal Security Service № 86, Ministry of Information Technologies and Communications of Russia № 20 dated 13 February 2008. "About the confirmation of the Procedure for the conduct of the classification of the informational systems of the personal data";
8) the order of the FSTEC of Russia dated 18 February 2013 № 21 "About the confirmation of the composition and content of the organizational and engineering controls concerning assurance of the security of the personal data at its processing in the informational systems of the personal data";
9) the order of the Federal Service for Supervision in the Sphere of Telecom, Information Technologies and Mass Communications dated 05 September 2013 № 996 "About confirmation of the personal income details and recommendations forms for its filling, format of the personal income details electronically, of the guides";
10) the order of the FTA dated 17 November 2010 № MMB-7-3/611 "About confirmation of the personal income details and recommendations forms for its filling, format of the personal income details electronically, of the guides".
11) Other statutory and regulatory enactments of the Russian Federation and requirements documents of the competent public authority.

4. Action plan with the personal data

During the processing of the PD the Operator will perform the following actions with the PD: the gathering, recording, systematization, accumulation, holding, improvement (upgrading, changing), extracting, use of, communication (distribution, delivery, access), sanitization, blocking, deletion, and destruction of personal data.

5. Composition of the processable personal data

5.1. The Operator processes the PD of the following PD owners:

  • the workers of the Operator;
  • the clients of the Operator;
  • the counterparties of the Operator;
  • the physical persons who have addressed to the Operator according to the procedure established by Federal law "About the order of consideration of the resorts of citizens of the Russian Federation".

5.2. The composition of the PD of each listed in the art. 5.1 of the present Regulation of the subjects' category is defined according to the requirements documents listed in part 3 of the present Regulation and also according to the requirements documents of the Company edited for the supporting of its execution.
5.3. In cases as stipulated by the current legislation the personal data owner accepts the decision to furnish his PD with the Operator and agrees to process this data without restraint, with his self-will and pursuing own benefit.
5.4. The operator furnishes the correspondence of the content and volume of the processable PD to the stated goals of the processing and in case of need he takes actions for the removal of its redundance in relation to the stated goals of the processing.
5.5. The processing of the special categories of the personal data concerning the ethnicity, national identity, political commitments, religions or philosophical views, intimate life in LLC "PRODUCTION COMPANY PROPLAST" is not realized.

6. Processing of personal data

6.1. The processing of the personal data in LLC "PRODUCTION COMPANY PROPLAST" is performed by the following methods:

  • the non-automated processing of personal data;
  • the automated processing of the personal data with the information production through the information and telecommunication networks or without it;
  • the miscellaneous treatment of the personal data.

7. Providing protection of the personal data at its processing by the Operator

The operator takes actions, which are necessary and sufficient for the enforcement of the performing duties prescribed by the Federal law dated 27 July 2006 № 152 FL "On Personal Data" and accepted in accordance with this FL statutory and regulatory enactments.
The operator has control over the composition and action items necessary and significant for the enforcement of the responsibilities prescribed by the Federal law dated 27 July 2006 № 152 "On Personal Data", the Decree of the Government dated 15 September 2008 № 687 "About the confirmation of the Regulation about the particularities of the processing of the personal data performed without the use of the automation facilities", the Decree of the Government of the Russian Federation dated 1 November 2012 № 1119 "About the affirmation of the security requirements of the personal records at its processing in the informational systems of the personal data", the order of the FSTEC dated 18 February 2013 № 21 "About the confirmation of the composition and content of the organizational and engineering controls concerning the assurance of the security of the personal data at its processing in the informational systems of the personal data" and other statutory and regulatory enactments if unless otherwise provided for by federal laws.
Among such measures are:
– the assignment by the Operator the responsible person for the organisation of the personal data processing;
– the documents publication by the Operator, which determine the policy of the operator concerning the processing of personal data, local acts regarding the questions of the processing of personal data and also the local acts, which install procedures directed to the prevention and disclosure of violations of the legislation of the Russian Federation, the damage limitation of such violations;
– the application of the legal, organizational and engineering arrangements concerning the assurance of the security of the personal data;
– the realization of the internal control and (or) the compliance audit of the processing of personal data to the Federal law "On Personal Data" and accepted in accordance with this FL statutory and regulatory enactments, security requirements to the personal data, policy of the Operator concerning the processing of the personal data, local acts of the Operator;
– the definition of the damage evaluation, which may be caused to the personal data owners in case of the violation of the Federal law "On Personal Data", the correspondence of the indicated damage and accepted measures by the operator directed to the performing of the duties prescribed by the Federal law "On Personal Data";
– the studying of the workers of the Operator who directly realize the processing of personal data, with the legislative provisions of the Russian Federation about the personal data including the security requirements of the personal data, documents, which determine the policy of the Operator concerning the processing of personal data, local acts on the questions of the processing of personal data and (or) the education of the indicated workers.
7.2. The operator at the processing of the personal data takes necessary legal, organizational and engineering arrangements or provides its acceptance for the protection of the personal data from the inappropriate or random-access to this data, destruction, change, blocking, copying, supplying, diffusion of the personal data and also from other inappropriate actions concerning the personal data.

8. Access right of the personal data owner to his personal data

8.1. The owner of the PD has a right to demand from the Operator to update his personal data, its blocking or destruction in case if the personal data is incomplete, outdated, imperfect, illegitimately received or is not necessary for the stated goal of the processing and also to make arrangements prescribed by the law for the self-assertion.
8.2. The data is offered to the personal data owner or to his representative by the operator during the treatment or on receipt of the personal data owner's demand or its representative. The demand must include the number of the basic document, which certifies the identity of the personal data owner or his representative, the details such as the date of issue of the present document and the issuing authority, information, which confirm the participation of the personal data owner in relationship with the Operator (the contract reference number, the contract date, the relative verbal mark and (or) other data), or data, which confirms the fact of the processing of personal data by the Operator otherwise, the signature of the personal data owner or his representative. The demand may be send in the form of the e-document and signed by the computer-generated signature subject to the laws of the Russian Federation.
8.3. The operator has a right to deny the personal data owner in the execution of the repeated requery. Such denial must be motivated. The obligation of the presentation of evidence of the foundation of the rejection in the execution of the repeated request rests on the Operator.
8.4. The personal data owner has a right to receive this information concerning the processing of his personal data including the information, which includes:
– the confirming of the fact of the processing of personal data by the Operator;
– the legal foundation and purposes of the processing of personal data;
– the purposes and using the personal data processing ways by the Operator;
– the name and location area of the Operator, data about the persons (besides the operator's workers), which have access to the personal data or to which the personal data may be disclosed based on the agreement with the operator or based on the federal law;
– the processable personal data concerning the corresponding personal data owner, its source if other production order of such data is not provided by the federal law;
– the time of the personal data processing including its storage time;
– the procedure for exercising by the personal data owner the rights provided by the Federal law "On Personal Data";
– the information about the executed or supposed cross-border data transmission;
– the title or family name, personal name, middle name and address of the person who performs the personal data processing by order of the Operator if the processing was delegated or will be delegate to such person.
8.5. If the personal data owner thinks that the operator realizes the processing of his personal data in contravention of the demands of the Federal law "On Personal Data" or otherwise infringes his rights and freedom, the personal data owner has a right to appeal against the actions or nonfeasance of the operator in the agency authorized on the questions of the protection of the rights of subjects of personal data or by judicial process.
8.6. The personal data owner has a right to the claim right and legal interests including the recovery of losses and (or) the compensation for moral injury through the courts.

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