In order that you as a service user and data controller (referred to as “Controller” or “User”) may use or continue to use the Medicinsk Optik (“Services”) offered by us, Medicinsk Optik of Kungsportsavenyen 33, 411 36 Göteborg, and data processor (referred to as “Medicinsk Optik” or “Processor”), you agree that certain Personal Data you submit as part of your use of our Services and these data processing terms (“Terms”) shall apply (notwithstanding any other terms and conditions applicable to the delivery of the Services to the contrary) in order to address the compliance obligations imposed upon Medicinsk Optik and its Users pursuant to Applicable Law.
1. DEFINITIONS
1.1. “Affiliate” means an entity that, directly or indirectly, controls, is controlled by, or is under common control with a Party. As used herein, “control” means the power to direct the management or affairs of an entity and the beneficial ownership of fifty percent (50%) or more of the voting equity securities or other equivalent voting interests of an entity.
1.2. “Applicable Law(s)” means all US, UK, and EU laws, regulations, and other legal or regulatory requirements relating to privacy, data protection/security, or the Processing of Personal Data applicable to Medicinsk Optik’s performance of its services under the Agreement,including without limitation the California Consumer Privacy Act, Cal. Civ. Code § 1798.100 et seq. (“CCPA”) as amended by the California Privacy Rights Act of 2020 (“CPRA”), including any implementing regulations, the United Kingdom Data Protection Act 2018, and the General Data Protection Regulation (Regulation (EU) 2016/679) (“GDPR”).
1.3. “User Contact Data” means the User’s contact information.
1.4. “User Personal Data” means User Data, as defined in the Agreement, consisting of Personal Data, except for User Contact Data.
1.5. “EEA” means, for purposes of this DPA, the European Economic Area (which is composed of the member states of the European Union), Norway, Iceland, Liechtenstein, and Switzerland.
1.6. “EU SCCs” means the Standard Contractual Clauses issued pursuant to the EU Commission Implementing Decision (EU) 2021/914 of 4 June 2021 on Standard Contractual Clauses for the transfer of personal data to third countries pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council, available at http://data.europa.eu/eli/dec_impl/2021/914/oj and completed as described in Section 9.
1.7. “Personal Data Breach” means the accidental or unlawful destruction, loss, alteration, or unauthorized disclosure of or access to User Personal Data.
1.8. “Personal Data” includes “personal data,” “personal information,” and “personally identifiable information,” each as defined by Applicable Law.
1.9. “Process” and “Processing” mean any operation or set of operations performed on Personal Data, or on sets of Personal Data, whether or not by automated means, such as collecting, recording, organizing, creating, structuring, storing, adapting or altering, retrieving, consulting, using, disclosing (by transmission, dissemination or otherwise making such data available), aligning or combining, restricting, erasing, or destroying such Personal Data.
1.10. “Standard Contractual Clauses” means the EU SCCs or the UK SCCs, as applicable.
1.11. “UK SCCs” means the International Data Transfer Addendum to the EU Commission Standard Contractual Clauses, available as of the Effective Date at https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/international-data-transfer-agreement-and-guidance/ and completed as described in Section 9.
2. RELATIONSHIP OF THE PARTIES
2.1. User is the Controller as defined under Applicable Laws, and User determines the means and purposes for which User Personal Data is Processed by Medicinsk Optik. To the extent Medicinsk Optik Processes User Personal Data subject to Applicable Laws, Medicinsk Optik is a Processor and Service Provider as defined under Applicable Laws, and Medicinsk Optik will Process the User Personal Data according to the instructions set forth in this DPA, the Agreement, and as required under Applicable Laws. User and Medicinsk Optik are independent Controllers, as defined under Applicable Laws, with respect to User Contact Data. Either Party may Process User Contact Data as necessary for the purpose of (i) carrying out its obligations under the Agreement, (ii) applicable legal or regulatory requirements, (iii) requests and communications with the other Party, (iv) administrative, business, and marketing purposes, and (v) to protect its respective rights in accordance with applicable law and, in the case of Medicinsk Optik, maintaining the security and integrity of the Services.
2.2. Medicinsk Optik hereby certifies that it understands the restrictions and obligations set forth in this DPA in relation to its role as a Processor and Service Provider, and that it will comply with them.
3. USER’S INSTRUCTIONS TO MEDICINSK OPTIK
3.1. Purpose Limitation. Medicinsk Optik will not:
3.1.1.sell or share (as defined by CCPA) User Personal Data,
3.1.2.Process User Personal Data for any purpose other than for the specific purposes set forth in the Agreement,
3.1.3.retain, use, or disclose any such data outside of the direct business relationship between the Parties,
3.1.4.combine any User Personal Data with personal information that it receives from, or on behalf of, another person or persons, or collects from its own interaction with a consumer, except as otherwise permitted by Applicable Law, or
3.1.5.otherwise engage in any Processing of User Personal Data beyond that in which a Processor may engage under the Applicable Law or in which a Service Provider may engage under the Applicable Law, unless obligated to do otherwise by Applicable Law. In such a case, Medicinsk Optik will inform User of the applicable legal obligation before engaging in the Processing, unless legally prohibited from doing so. Further details regarding Medicinsk Optik’s Processing operations are set forth in Schedule 1. To the extent User discloses or makes available deidentified data (as such term is defined under Applicable Law) within the User Data to Medicinsk Optik, Medicinsk Optik shall not attempt to re-identify such data.
3.2. Lawful Instructions. User will not instruct Medicinsk Optik to Process User Personal Data in violation of Applicable Law. Medicinsk Optik will without undue delay inform User if, in Medicinsk Optik’s opinion, an instruction from User infringes Applicable Law. The Agreement, including this DPA, constitutes User’s complete and final instructions to Medicinsk Optik regarding the Processing of User Personal Data, including for purposes of the Standard Contractual Clauses. User shall also have the right to take reasonable and appropriate steps to stop or remediate any unauthorized Processing of User Personal Data by Medicinsk Optik.
4. LIMITATIONS ON DISCLOSURE
Medicinsk Optik will not disclose User Personal Data to any third party without first obtaining User’s written consent, except as provided in Section 5, Section 7 or Section 9, except as required by law. Medicinsk Optik will require all employees, contractors, and agents who Process User Personal Data on Medicinsk Optik’s behalf to protect the confidentiality of the User Personal Data and to comply with the other relevant requirements of this DPA.
5. SUBCONTRACTING
5.1. Sub-Processors. Medicinsk Optik may subcontract the collection or other Processing of User Personal Data only in compliance with Applicable Law and any additional conditions for subcontracting set forth in the Agreement. User acknowledges and agrees that Medicinsk Optik’s Affiliates and certain third parties may be retained as sub-processors to Process User Personal Data on Medicinsk Optik’s behalf (under this DPA as well as under the Standard Contractual Clauses, if they apply) in order to provide the Services.
5.2. Prior to a sub-processor’s Processing of User Personal Data, Medicinsk Optik will impose contractual obligations on the sub-processor substantially the same as those imposed on Medicinsk Optik under this DPA to the extent applicable to the nature of the services provided by such sub-processor. Medicinsk Optik remains liable for its sub-processors’ performance under this DPA to the same extent Medicinsk Optik is liable for its own performance.
5.3. Notification. Medicinsk Optik will provide Users with at least ten (10) days’ written notice of new sub-processors before authorizing such sub-processor(s) to Process User Personal Data in connection with the provision of the Services. Medicinsk Optik will notify User at the email address provided in the signature block of this DPA for purposes of this notification. The sub-processor agreements to be provided under Section 5(j) of the EU SCCs may have all commercial information, or provisions unrelated to the EU SCCs, redacted prior to sharing with User, and User agrees that such copies will be provided only upon written request.
5.4.Right to Object. User may object to Medicinsk Optik’s use of a new sub-processor on reasonable grounds relating to the protection of User Personal Data by notifying Medicinsk Optik promptly in writing within ten (10) business days after receipt of Medicinsk Optik’s notice in accordance with the mechanism set out in Section 5.2. In its notification, User will explain its reasonable grounds for objection. In the event User objects to a new sub-processor, Medicinsk Optik will use commercially reasonable efforts to make available to User a change in the Services or recommend a commercially reasonable change to User’s configuration or use of the Services to avoid Processing of User Personal Data by the objected-to new sub-processor without unreasonably burdening User. If Medicinsk Optik is unable to make available such change within a reasonable period of time, which will not exceed thirty (30) days, either Party may terminate without penalty the Processing of User Personal Data and/or the Agreement with respect only to those services which cannot be provided by Medicinsk Optik without the use of the objected-to new sub-processor by providing written notice to the other Party.
6. ASSISTANCE AND COOPERATION
6.1. Security. Medicinsk Optik will provide reasonable assistance to User regarding User’s compliance with its security obligations under Applicable Law relevant to Medicinsk Optik’s role in Processing User Personal Data, taking into account the nature of Processing and the information available to Medicinsk Optik, by implementing the technical and organizational measures set forth in Schedule 2, without prejudice to Medicinsk Optik’s right to make future replacements or updates to the measures that do not materially lower the level of protection of User Personal Data. Medicinsk Optik will ensure that the persons Medicinsk Optik authorizes to Process the User Personal Data are subject to written confidentiality agreements or are under an appropriate statutory obligation of confidentiality no less protective than the confidentiality obligations set forth in the Agreement.
6.2. Personal Data Breach Notification & Response. Medicinsk Optik will comply with the Personal Data Breach-related obligations directly applicable to it under Applicable Law. Taking into account the nature of Processing and the information available to Medicinsk Optik, Medicinsk Optik will inform User of a substantiated Personal Data Breach without undue delay or within the time period required under Applicable Law, and in any event no later than seventy-two (72) hours following such substantiation. Medicinsk Optik will notify User at the email address provided in the signature block of this DPA for purposes of Personal Data Breach notifications. Any such notification is not an acknowledgement of fault or responsibility. This notification will include Medicinsk Optik’s then-current assessment of the following information, to the extent available, which may be based on incomplete information:
6.2.1. the nature of the Personal Data Breach, including, where possible, the categories and approximate number of data subjects concerned and the categories and approximate number of User Personal Data records concerned;
6.2.2. the likely consequences of the Personal Data Breach; and
6.2.3. measures taken or proposed to be taken by Medicinsk Optik to address the Personal Data Breach, including, where applicable, measures to mitigate its possible adverse effects.
6.3. Medicinsk Optik will provide timely and periodic updates to User as additional information regarding the Personal Data Breach becomes available. User is solely responsible for complying with legal requirements for incident notification applicable to User and fulfilling any third-party notification obligations related to any Personal Data Breach. Nothing in this DPA or in the Standard Contractual Clauses will be construed to require Medicinsk Optik to violate, or delay compliance with, any legal obligation it may have with respect to a Personal Data Breach or other security incidents generally.
7. DATA SUBJECT REQUESTS
To the extent legally permitted, Medicinsk Optik will without undue delay notify User if Medicinsk Optik receives any request from an individual seeking to exercise any right afforded to them under Applicable Law regarding their Personal Data (a “Data Subject Request”). To the extent User, in its use of the Services, does not have the ability to address a Data Subject Request, Medicinsk Optik will, upon User’s request, take commercially reasonable efforts to assist User in responding to such Data Subject Request, to the extent Medicinsk Optik is legally permitted to do so and the response to such Data Subject Request is required under Applicable Law.
8. DPIAS AND CONSULTATION WITH AUTHORITIES
Upon User’s written request, Medicinsk Optik will provide User with reasonable cooperation and assistance as needed and appropriate to fulfill User’s obligations under Applicable Law to carry out a data protection impact assessment related to User’s use of the Services. Medicinsk Optik will provide reasonable assistance to User in the cooperation or prior consultation with the Supervisory Authority (as defined under the GDPR) in the performance of its tasks relating to the data protection impact assessment, and to the extent required under the Applicable Law.
9. INTERNATIONAL DATA TRANSFERS
9.1. User authorizes Medicinsk Optik and its sub-processors to make international transfers of the User Personal Data in accordance with this DPA so long as Applicable Law for such transfers is respected.
9.2. With respect to User Personal Data transferred from the EEA, the EU SCCs will apply and form part of this DPA, unless the European Commission issues updates to the EU SCCs, in which case the updated EU SCCs will control. Undefined capitalized terms used in this provision will have the meanings given to them (or their functional equivalents) in the definitions in the EU SCCs. For purposes of the EU SCCs, they will be deemed completed as follows:
9.2.1. Where User acts as a Controller and Medicinsk Optik acts as User’s Processor with respect to User Personal Data subject to the EU SCCs, Module 2 applies.
9.2.2. Where User acts as a Processor and Medicinsk Optik acts as User’s sub-processor with respect to User Personal Data subject to the EU SCCs, Module 3 applies.
9.2.3. Section 7 (the optional docking Section) is not included.
9.2.4. Under Section 9 (Use of sub-processors), the Parties select Option 2 (General written authorization). The initial list of sub-processors is set forth at Section 5. Medicinsk Optik will provide notice of updates to that list at least ten (10) business days in advance of any intended additions or replacements of sub-processors, in accordance with Section 5 of this DPA.
9.2.5. Under Section 11 (Redress), the optional requirement that data subjects be permitted to lodge a complaint with an independent dispute resolution body is inapplicable.
9.2.6. Under Section 17 (Governing law), the Parties select Option 1 (the law of an EU Member State that allows for third-party beneficiary rights). The Parties select the law of Sweden.
9.2.7. Under Section 18 (Choice of forum and jurisdiction), the Parties select the courts of Sweden.
9.2.8. Annexes I and II of the EU SCCs are set forth in Schedule 1 below.
9.2.9. Annex III of the EU SCCs (List of sub-processors) is inapplicable.
9.2.10. By entering into this DPA, the Parties are deemed to be signing the EU SCCs.
9.3. With respect to User Personal Data transferred from the United Kingdom for which the law of the United Kingdom (and not the law in any European Economic Area jurisdiction) governs the international nature of the transfer, the UK SCCs form part of this DPA and take precedence over the rest of this DPA as set forth in the UK SCCs, unless the United Kingdom issues updates to the UK SCCs, in which case the updated UK SCCs will control. Undefined capitalized terms used in this provision will have the meanings given to them (or their functional equivalents) in the definitions in the UK SCCs. For purposes of the UK SCCs, they will be deemed completed as follows:
9.3.1. Table 1 of the UK SCCs:
9.3.1.1. The Parties’ details are the Parties and their affiliates to the extent any of them is involved in such transfer, including those set forth in Schedule 1.
9.3.1.2. The Key Contacts are the contacts set forth in Schedule 1.
9.3.2. Table 2 of the UK SCCs: The Approved EU SCCs referenced in Table 2 are the EU SCCs as executed by the Parties pursuant to this Addendum.
9.3.3. Table 3 of the UK SCCs: Annex 1A, 1B, and II are set forth in Schedule 1.
9.3.4. Table 4 of the UK SCCs: Either Party may terminate this Addendum as set forth in Section 19 of the UK SCCs.
9.4. By entering into this DPA, the Parties are deemed to be signing the UK SCCs and their applicable Tables and Appendix Information.
9.5. With respect to User Personal Data transferred from Switzerland for which Swiss law (and not the law in any European Economic Area jurisdiction) governs the international nature of the transfer, the EU SCCs will apply and will be deemed to have the following differences to the extent required by the Swiss Federal Act on Data Protection (“FADP”):
9.6. References to the GDPR in the EU SCCs are to be understood as references to the FADP insofar as the data transfers are subject exclusively to the FADP and not to the GDPR.
9.7. The term “member state” in the EU SCCs will not be interpreted in such a way as to exclude data subjects in Switzerland from the possibility of suing for their rights in their place of habitual residence (Switzerland) in accordance with Section 18(c) of the EU SCCs.
9.8. References to Personal Data in the EU SCCs also refer to data about identifiable legal entities until the entry into force of revisions to the FADP that eliminate this broader scope.
9.9. Under Annex I(C) of the EU SCCs (Competent supervisory authority): where the transfer is subject exclusively to the FADP and not the GDPR, the supervisory authority is the Swiss Federal Data Protection and Information Commissioner, and where the transfer is subject to both the FADP and the GDPR, the supervisory authority is the Swiss Federal Data Protection and Information Commissioner insofar as the transfer is governed by the FADP, and the supervisory authority is as set forth in the EU SCCs insofar as the transfer is governed by the GDPR.
10. AUDITS
Medicinsk Optik will allow for and contribute to audits, including inspections, conducted by User or another auditor mandated by User subject to the following conditions: so long as the Agreement remains in effect, User may request that Medicinsk Optik provide it with Medicinsk Optik’s most recent information security reports no more than once annually relating to Medicinsk Optik’s compliance with this DPA (an “Audit”). To the extent User uses a third-party representative at User’s sole expense to conduct the Audit, User will ensure that such third-party representative is bound by obligations of confidentiality no less protective than those contained in the Agreement. User will provide Medicinsk Optik with ninety (90) business days prior written notice of its intention to conduct an Audit. User will conduct the Audit in a manner that will result in minimal disruption to Medicinsk Optik’s business operations and such Audit will take no longer than two (2) business days. Further, User will not be entitled to receive data or information of other Users of Medicinsk Optik or any other Confidential Information of Medicinsk Optik that is not directly relevant for the authorized purposes of the Audit.
11. LEGAL PROCESS
If Medicinsk Optik is legally compelled by a court or other government authority to disclose User Personal Data, then to the extent permitted by law, Medicinsk Optik will promptly provide User with sufficient notice of all available details of the legal requirement and reasonably cooperate with User’s efforts to challenge the disclosure, seek an appropriate protective order, or pursue such other legal action, as Medicinsk Optik deems appropriate.
12. DESTRUCTION OF PERSONAL DATA
Upon termination of the Agreement and written request from User, Medicinsk Optik will delete or anonymize User Personal Data, unless prohibited by Applicable Law. Notwithstanding the foregoing, nothing will oblige Medicinsk Optik to delete or anonymize User Personal Data from files created for security, backup and business continuity purposes sooner than required by Medicinsk Optik’s data retention processes. Any User Personal Data that may be retained beyond the duration of the Agreement will still be protected in accordance with this DPA and Medicinsk Optik shall not process such User Personal Data except as strictly permitted under Applicable Law.
13. APPLICABILITY AND ORDER OF PRECEDENCE
This DPA replaces any existing data processing addendum the Parties may have previously entered into in connection with the Agreement. In the event of a conflict between the terms of the Agreement and this DPA, the terms of the DPA will apply. In the event of a conflict between this DPA and the applicable Standard Contractual Clauses, the Standard Contractual Clauses will apply.
SCHEDULE 1
Annexes I and II of the EU SCCs
1. List of Parties
1.1.1. Module Two: Transfer Controller to Processor
1.1.2. Module Three: Transfer Processor to Processor
1.2. Data exporter(s):
1.2.1. Name: The exporter is the User specified in the Agreement.
1.2.2. Address: specified in the Agreement.
1.2.3. Contact person’s name, position and contact details: specified in the Agreement.
1.2.4. Activities relevant to the data transferred under these Sections: Obtaining the Services from data importer.
1.2.5. Role (Controller/Processor): Controller
1.3. Data importer(s):
1.3.1. Name: Medicinsk Optik, Schiemond 20, 3024EE, Rotterdam, NL
1.3.2. Address: specified in the Agreement.
1.3.3. Contact person’s name, position and contact details: specified in the Agreement.
1.3.4. Activities relevant to the data transferred under these Sections: Providing the Services to data exporter.
1.3.5. Role (Controller/Processor): Processor
2. Description of Transfer
2.1. Module Two: Transfer Controller to Processor
2.2. Module Three: Transfer Processor to Processor
3. Categories of data subjects whose personal data is transferred
3.1. Data subjects whose Personal Data is uploaded by data exporter to, or otherwise received directly or indirectly from data exporter by or through, the Services, or provided by data exporter to Medicinsk Optik to input into the Services.
4. Categories of personal data transferred
4.1. The data exporter may transfer Personal Data to Medicinsk Optik, the extent of which is determined and controlled by the data exporter in its sole discretion. Such Personal Data may include any category of Personal Data the data exporter may enter into the Services.
4.2. Sensitive data transferred and applied restrictions or safeguards that fully take into consideration the nature of the data and the risks involved, such as for instance strict purpose limitation, access restrictions (including access only for staff having followed specialized training), keeping a record of access to the data, restrictions for onward transfers or additional security measures.
5. The frequency of the transfer
5.1. Continuously, for the length of the Agreement between the Parties.
6. Nature of the processing
6.1. User Personal Data transferred will be processed to (i) provide the Services to the data exporter and fulfill the data importer’s obligations under the Agreement; and (ii) comply with applicable law.
7. Purpose(s) of the data transfer and further processing
7.1. User Personal Data transferred will be processed to (i) provide the Services to the data exporter and fulfill the data importer’s obligations under the Agreement; and (ii) comply with applicable law.
8. The period for which the personal data will be retained
8.1. User Personal Data will be retained for the length of time necessary to provide Services under the Agreement and in accordance with Medicinsk Optik’s data retention processes and as otherwise required by applicable law.
9. For transfers to (sub-)processors, also specify subject matter, nature and duration of the processing
9.1. Medicinsk Optik’s sub-processors will process User Personal Data to assist Medicinsk Optik in providing the Services pursuant to the Agreement, for as long as needed for Medicinsk Optik to provide the Services.
10. Competent Supervisory Authority
10.1. Module Two: Transfer Controller to Processor
10.2. Module Three: Transfer Processor to Processor
11. Identify the competent supervisory authority/ies in accordance with Section 13
11.1. The Parties will follow the rules for identifying such authority under Section 13 and, to the extent legally permissible, select the Swedish Authority for Privacy Protection’s (IMY).
SCHEDULE 2
TECHNICAL AND ORGANIZATIONAL MEASURES
Description of the technical and organizational measures implemented by the data importer(s) to ensure an appropriate level of security, taking into account the nature, scope, context, and purpose of the processing, and the risks for the rights and freedoms of natural persons.
1. ACCESS CONTROLS
1.1. System Access Controls: Medicinsk Optik has implemented measures including role-based access, unique user accounts, strong password requirements, authentication protocols, access provisioning/removal, and periodic reviews.
1.2. Physical Access Controls: Managed by cloud hosting providers with key card systems, 24/7 guards, fire suppression, and redundancy protocols. Annual review of provider compliance reports is performed.
2. OPERATIONS MANAGEMENT AND NETWORK SECURITY
2.1. Network segmentation and firewall protection.
2.2. Regular patch management and vulnerability scans.
3. CHANGE MANAGEMENT
3.1. Formal change control process including security assessments and approvals.
3.2. Secure development lifecycle aligned with OWASP standards.
3.3. Secure coding and deployment training for developers.
4. DATA ENCRYPTION AND DELETION
4.1. Encryption at rest and in transit using industry standards.
4.2. Disk encryption, strong authentication, and session locking for employee workstations.
4.3. Data deletion procedures aligned with legal requirements and ISM guidance.
5. SUB-PROCESSORS
5.1. Sub-processor due diligence and contractual obligations enforced.
5.2. Annual audits and reviews of sub-processors’ security and privacy compliance.
6. SYSTEM MONITORING AND VULNERABILITY MANAGEMENT
6.1.1. Use of intrusion detection methods to prevent and identify potential security attacks from users outside the boundaries of the system.
6.1.2. Performance of automated application and infrastructure vulnerability scans to identify vulnerabilities, classification of vulnerabilities using industry standards, and remediation of vulnerabilities based on severity level.
6.1.3. Annual third-party penetration testing (an executive summary can be provided upon request).
6.1.4. Risk assessments and continuous monitoring of Medicinsk Optik’s risk register.
6.1.5. Periodic third-party security audits.
6.1.6. Monitoring, logging, and reporting on critical or suspicious activities with regard to network devices, including retention of logs for forensic-related analysis, maintenance of audit logs that record and examine activity within Medicinsk Optik’s production environment, back-up of logs in real time, and implementation of controls to prevent modification or tampering of logs.
6.1.7. Operation of a “bug bounty” program to identify potential security vulnerabilities.
6.1.8. Deployment of anti-virus and malware tools to detect and remediate harmful code or programs that can negatively impact the Services.
7. PERSONNEL CONTROLS
7.1. Medicinsk Optik uses reasonable efforts to ensure the continued reliability of employees who have access to User Data by implementing the following measures:
7.1.1. Conducting background checks, subject to applicable laws, on all employees who may access User Data.
7.1.2. Requiring employees to complete new-hire security training and acknowledge Medicinsk Optik’s information security policies, including but not limited to Medicinsk Optik’s Code of Conduct and Acceptable Use of Technology Resources Policy, upon hire.
7.1.3. Requiring employees to complete annual privacy and security training covering topics that address their obligations to protect User Data as well as privacy and security best practices.
7.1.4. Instructing employees to report potential personal data breaches to the Security team.
7.1.5. Imposing discipline for material violations of Medicinsk Optik’s information security policies.
8. BACKUPS, BUSINESS CONTINUITY, AND DISASTER RECOVERY
8.1. Backups:
8.1.1. Medicinsk Optik maintains a policy and procedure for performing backups of User Data.
8.2. Business Continuity Program:
8.2.1. Medicinsk Optik maintains a reasonable business continuity program, including a disaster recovery plan, designed to minimize disruption to the Services. The plans are tested annually and the process is amended as needed.
9. AUDIT REVIEW
Upon User’s written request (email to suffice), Medicinsk Optik will provide to User for review a copy of Medicinsk Optik’s most recent annual audit results.