Client Record Management Policy & Procedures

INFORMATION & CLIENT RECORDS MANAGEMENT POLICY

Website Privacy Policy

Valid as of …………… 2023.

1. PRIVACY POLICY

1.2. POLICY STATEMENT

ANIMAYACHTING.COM Platform (“animayachting.com”) is a travel platform, operated by «ANIMA RIBS ΜΟΝΟΠΡΟΣΩΠΗ ΙΚΕ» operating under the business name «ANIMA RIBS» is a travel agency, with offices on Thnou 2a 15562, tel. +30 2106534769 email: info@animayachting.com (registration no “G.E.MI”. 169587103000).

ANIMA YACHTING holds all the rights of ANIMAYACHTING.COM concerning intellectual and industrial property, under the international intellectual property law. ANIMA YACHTING is committed to protecting and upholding the right to privacy of clients, staff, and external collaborators we deal with. In particular ANIMA YACHTING through ANIMAYACHTING.COM, is committed to protecting and upholding the rights of our clients to privacy in the way we collect, store and use information about them, their needs and the services we provide to them.

ANIMA YACHTING requires from its own staff and the employees of its collaborators to be consistent and careful in the way they manage client information.

ANIMA YACHTING, through ANIMAYACHTING.COM, will ensure that:

it meets its legal and ethical obligations as a service provider in relation to protecting the privacy of clients.
clients are provided with information about their rights regarding privacy.
all staffmembers of the ANIMA YACHTING understand what is required in meeting these obligations.

This policy will apply to all recordscontaining personal information about individuals. This policy requires to be read and understood in conjunction with ANIMAYACHTING.COM PRIVACY POLICY (link to privacy policy)

2. INFORMATION & CLIENT RECORDS MANAGEMENT POLICY

2.1. CLIENT RECORDS POLICY

2.1.1. POLICY STATEMENT

ANIMA YACHTING is committed to collecting, keeping and disposing of client records through ANIMAYACHTING.COM, in ways that protect privacy and ensure confidentiality is maintained. This policy will operate in conjunction with the company’s Privacy Policy. The Company complies with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation or GDPR) and the applicable national data protection legislation which governs the collection, use and storage of personal information.

Specifically, ANIMA YACHTING will:

collect and keep information about clients only when it is relevant and necessary to the provision of the servicean the purpose of processing as described in the Privacy Policy. As “clients”, are considered all natural persons, users of the ANIMAYACHTING.COM platform (“client”).
ensure data about each client is up to date, accurate and secure, whether stored in hard copy or electronically, in accordance with privacy legislation.
store clients’ records for the required length of time as this is determined by the nature of the processing.
transfer or dispose of client records correctly.
provide information to clients about how their personal information is managed.

When ANIMA YACHTING collects, keeps and uses personal data about a client through ANIMAYACHTING.COM, the following procedures will be implemented to guarantee the privacy of the client and to ensure that records are appropriate, accurate and secure.

2.1.2. WHO THE ANIMA YACHTING CLIENT RECORDS POLICY APPLIES TO:

Members of the ANIMA YACHTING Board
ANIMA YACHTING management
ANIMA YACHTING employees

2.1.3. PROCEDURE

2.1.3.1. Collecting identifiable data

ANIMA YACHTING collects and records the following information about clients:

Contact Information: name, address, telephone number, email address
Personal Information: gender, age, ID or passport Information, destination, origin, minors’ personal data
Service-related information– locations, dietary restrictions, pharmaceutical and medicine information, ticket numbers, reservations, hotel rooms, board cards, museum pass

This information is collected for the purpose of:

provision of the service requested
developing an accurate client record and client file for delivering the services requested
monitoring and management of client service quality

The competent staff will review the scope of information collected on clients to ensure that only relevant information is being recorded in order to enable us to offer the service and in compliance with our Privacy Policy. If additional information is being sought from clients, the staff member seeking the information will provide the information and inform the clients of:

the reason for requesting the information
how the information will be recorded and stored
what other information will be recorded during the provision of service
how their privacy will be protected
their rights to access, rectify or deletethe data stored about them.

If personal information about a client will be shared with another agency, the ANIMA YACHTING authorized employee will inform the client about the recipient and the reason for the transfer and, if necessary, obtain the client’s consent for this and record the date of the verbal consent/obtain the client’s signature on a consent form.

2.1.3.2. Storage and use of personal data

Information collected about clients is stored in the following ways:
- The ANIMAYACHTING.COM electronic client document management system dataare stored in the cloud( provide information about the cloud, location of servers, separate folders dedicated to animayachting.com etc). Access to the clients’ data is based upon permissions being given by the RecordsAdministrator. The permissions are granted to relevant staff for access to particular sections of the clientsrecords. At all levels access is permission dependant and user name & password protected.
- ANIMA YACHTING, through ANIMAYACHTING.COM,is given full access to all levels and functions within the electronic records system.
- Only the Records Administrator and staff directly engaged in the provision of services granted the relevant permissions by the RecordsAdministrator can access client information in the electronic system.
The ANIMA YACHTING General Manager or their delegate is authorised to access electronic client files for all clients and past clients of ANIMA YACHTING services.
Individual Service Coordinators are authorised to access the hard copy and soft copy client files/records for clients in their specific services/programs
Staff of ANIMA YACHTING, involved in the delivery of service to clients, may have access to the individual client file on the authorisation of the specific Service Coordinator. In the absence of a Service Coordinator permission to access a client file may be granted by the ANIMA YACHTING General Manager.
Clients can have access their files. ANIMA YACHTING will address these requests, along with any request to exercise data subject’s right under GDPR according to the company’s Data Subject Rights Procedure. ANIMA YACHTING will assist ANIMAYACHTING.COM platform in any way avaible to address and fulfill any such request by a client.

2.1.3.3. Maintaining and verifying client records

ANIMA YACHTING has defined a competent employee whois responsible for ensuring review and update of client records. Client records will be updated on timed intervals. Routinely, client records will be reviewed and updated at a minimum twelve (12) months interval for active clients.

A file will be created for each client, and used to record:

General Client Information- name, address, gender, age, contact details,
Service delivery details -specific requests, other relevant service assessments/correspondence (see above)

In recording personal information about clients, ANIMA YACHTING will ensure that:

The details are correct and accurate and verified by the client
The details being recorded are appropriate using appropriate and professional language and descriptors

2.1.3.4. File management

The relevant position/title of competent employee or staffof ANIMA YACHTING is responsible for ensuring and managing the filing of client records, maintaining the registry/list of client records and managing the archiving and disposal of client records. ANIMA YACHTING records are maintained for Ten (10) years depending on the requirements of the individual service or client request and then disposed of in line with the principles established by GDPR.

ANIMA YACHTING will maintain an updated annual list of current clientsindicating whether they are activeor requested to be removed from the list). The position/title of competent employee or staffis responsible for ensuring the maintenance of this information and the accuracy of the recorded client information and data.

The ANIMA YACHTING client documentation management system will store all client data in the cloud in the individual client folder for clients. This system will capture all information relevant to the service provided to each client, the clients personal data, client notes and updates, client consents( if needed), individual client requests.

2.1.3.5. Recorddisposal

ANIMA YACHTING financial and tax records are kept for 10 years from the date of transaction .
General client records are kept for 18 months from the last point for service provision.

After the specific retention period General client records are safely destroyed according to the company’s Retention & Destruction Policy.

Records of clients who requested their data to be erased are safely destroyed according to the company’s Retention & Destruction Policy.

2.2. ACCESS TO CONFIDENTIAL INFORMATION POLICY

2.2.1. POLICY STATEMENT

ANIMA YACHTING is committed to transparency in its operations and strives to balance upholding the rights of individuals to privacy and company’s confidentialcorporatematters.

ANIMA YACHTING will prevent unauthorised persons accessing a client’s records and enable clients to exercise their rights under GDPR. This policy applies to client records and unpublished materials of ANIMA YACHTING through ANIMAYACHTING.COM .

2.2.2. WHO THE ANIMA YACHTING CLIENT RECORDS POLICY APPLIES TO:

Members of the ANIMA YACHTING Board
ANIMA YACHTING management
ANIMA YACHTING employees

2.2.3. PROCEDURE

2.2.3.1. Client records

Client records will be confidential to clients and to those ANIMA YACHTING staff members directly engaged in delivery of service to the client(s).

Information about clients may only be made available to other parties only when it is necessary for the performance of the contract and the provision of the service requested, when it is mandated by a legal provision or with the consent of the client or their duly guardian or legal representative, according to the ANIMA YACHTING Privacy Policy.

ANIMA YACHTING is operating in a cloud based electronic records system. Client personal data and service details will be contained within separate folders. Access to the clients’ electronic folders is username & password protected with varying levels of access allocated depending on the designation of the staff member and the level of information access required.

2.2.3.2. Requests for access – client records

All clients and former clients have the right to access their records and advise the company about inaccuracies. ANIMA YACHTING will ensure that:

clients are aware of their rights around access to their records and are given appropriate and ready access to their information
Any inaccuracies identified by the client will be noted and amended accordingly by the relevant staff member
in the event a client request to access their file is refused by ANIMA YACHTING, adequate explanation will be provided for such refusal.

All request for the exercise of the clients’ rights under the GDPR will be processed according to Data Subjects’ Rights which are included in ANIMA YACHTING Privacy Policy.