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Extract to table / dpia-007-marketing-profiling.docx
dpia-007-marketing-profiling.docx
Parties
Harkness LLP
Northgate Telecommunications PLC
Northgate Ireland Ltd
Ashdown Consulting Group Ltd
NTP PLC
Northgate GmbH
Northgate France SAS
Pinnacle Cloud Services Ltd
Dates
Amounts
Obligations
3 Legal Basis for Conducting This DPIA The legal obligation to conduct this DPIA arises from Article 35(1) of the UK GDPR and EU GDPR, which provides that where a type of processing, in particular using new technologies and taking into account the nature, scope, context, and purposes of the processing, is likely to result in a high risk to the rights and freedoms of natural persons, the controller shall, prior to the processing, carry out an assessment of the impact of the envisaged processing operations on the protection of personal data
The consent mechanisms deployed on the NorthCloud freemium tier must be fundamentally redesigned to meet the requirements of Article 6(1)(a), Article 7, and Recital 32 of the UK GDPR and EU GDPR
Consent must be freely given, specific, informed, and unambiguous, and must be demonstrated by a clear affirmative action
The right to object to processing for direct marketing purposes, including profiling to the extent that it is related to such direct marketing, is an absolute right that must be available to data subjects prominently and easily