Data protection policy - International Human Resources
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Data protection policy

Data protection policy

Last updated – May 2018


IHR means International Human Resources OOD (Ltd.), with registered address  in Sofia, Bulgaria, 12, Yuri Venelin, str., and office address Sofia, Bulgaria, 1, Malyovitsa str. UIC 130585183

GDPR means the General Data Protection Regulation

Responsible Person means email:


IHR needs to gather and use certain information about individuals. These can include customers, suppliers, business contacts, employees, students and other people the organization has a relationship with or may need to contact.

This policy describes how this personal data must be collected, handled and stored to meet the company’s data protection standards – and to comply with the law.


Why this policy exists

This data protection policy ensures IHR:

  • Complies with data protection law and follows good practice
  • Protects the rights of staff, customers, students  and partners
  • Is open about how it stores and processes individuals’ data
  • Protects itself from the risks of a data breach



This policy applies to all parties (customers, suppliers, employees, job candidates, students, etc.) who provide any amount of information to us. Employees are obliged to follow this policy. Contractors, consultants, partners and any other external parties are also covered. Generally, our policy refers to anyone we collaborate with or acts on our behalf and may need occasional access to data.


Data protection principles

IHR is committed to processing data in accordance with its responsibilities under the GDPR.

Article 5 of the GDPR requires that personal data shall be:

  1. processed lawfully, fairly and in a transparent manner in relation to individuals;
  2. collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;
  3. adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
  4. accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;
  5. kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals; and
  6. processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.”


General provisions

  1. This policy applies to all personal data processed by IHR.
  2. The Responsible Person shall take responsibility for IHR’s ongoing compliance with this policy.
  3. This policy shall be reviewed at least annually.
  4. Data we process will not be communicated informally, transferred to organizations or countries that do not have adequate data protection policies and distributed in any manner not permitted by law


Lawful, fair and transparent processing

  1. To ensure its processing of data is lawful, fair and transparent, IHR shall maintain a Register of Systems.
  2. The Register of Systems shall be reviewed at least annually.
  3. Individuals have the right to access their personal data and any such requests made to IHR shall be dealt with in a timely manner.


Lawful purposes

  1. All data processed by IHR must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests.
  2. IHR shall note the appropriate lawful basis in the Register of Systems.
  3. Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data.
  4. Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent should be clearly available and systems should be in place to ensure such revocation is reflected accurately in IHR’s systems.


Data minimisation

  1. IHR shall ensure that personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
  2. IHR shall periodically review its` processing to check that the personal data held is still relevant and adequate for the purposes data is collected, and delete anything no longer needed.



  1. IHR shall take reasonable steps to ensure personal data is accurate.
  2. Where necessary for the lawful basis on which data is processed, steps shall be put in place to ensure that personal data is kept up to date.


Archiving / removal

  1. To ensure that personal data is kept for no longer than necessary, IHR shall put in place an archiving policy for each area in which personal data is processed and review this process annually.
  2. The archiving policy shall consider what data should/must be retained, for how long, and why.



  1. IHR shall ensure that personal data is stored securely using modern software that is up-to-date.
  2. Access to personal data shall be limited to personnel who need access and appropriate security should be in place to avoid unauthorised sharing of information.
  3. When personal data is deleted this should be done safely such that the data is irrecoverable.
  4. Appropriate back-up shall be in place.



In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data, IHR shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach to the supervisory authority.