INVENTORY GROUP STATUS 2016

DOUBT/COMMENT

There is also switch and third parties involved in Line F.

Find some work solution for areas that have no

representativeness

We included here newletters as e-mail shootings, however:

> This is outbound, not inbound
> We dont collect personal data
> its just instead the usage of personal data.
Please make sure whats the real scope and what we should do

In the cell DC-C-12 is the entry Paper Mailing for line F is

correct? Because it sais in the description that "A consumer can
register to the F-line on the site through a web form". Thus, if its
through a web form, the entry point shouldnt be paper.

Helping suggestion from Portugal to Marketing:

Theres a need of considering in the document, some collect
pages as the following examples

All the check-boxes for e-mail communication must be

inventoried? Or just the the check box regarding the legal
mention?

When a consumer sends a paper letter to ask help or to

complaint > Is this an entry point for data collection?

Theres a need of a good revision on the documents functions

10

"Facebook Management" for I&S and SAI is another entry point

because these areas receives everyday consumers doubts and
data coming from this channel (private messages p.e)

11

There is a telephone line to where a consumer can call to ask

for a freebook. Is this entry point inventoried?

12

For cookies: the way a user accepts the cookies usage is a link
written "ok i accept" > what kind of legal opt is this?

13

"External Use" is just applied to PRP/3th partiess cases?

US 2016
EXAMPLES
Example (need to be logged in)
https://www.deco.proteste.pt/investe/interactive/switch/?switch=FundPortfolio
Then the user is redirected to our partner
https://www.optimize.pt/Subscrever.html

> http://www.deco.proteste.pt/institucionalemedia/> http://www.condominiodeco.pt/> Telemarking (external

(dont do the log in)

https://www.deco.proteste.pt/investe/montepio-super-deposito-maiss5106364.htm
https://ofertasaude.deco.proteste.pt/index.aspx?prm_id_c=PTNLNMTS

RESOLUTION PROCESS
STEP 1

STEP 2

PRP needs to be aware of this revision detail,

towards all countries

PRP needs to put in the "Third Parties sheet"

the names of more partners which came from
Line F
(if founded/ some could be equal)

All countries must contribute with examples

Who can do the exceptional revision

Confirm with the steering.

Please give us 4/5 examples of what could
seem personal data and it is not.

If considered an error, retify the line

Check if theres another cell/code for the real

Line F web form (https://invest.testachats.be/index.aspx?)
I think there is in DC-C-11

If agreed, putting this type of cases in the

inventory xls.

If agreed, search for similar cases towards all

countries

Confirm with the steering.

If agreed, putting this type of cases in the

inventory xls. Guarantee this revision and the
appropriate timing to do it.

Make sure if it should be inventoried

Have the overall group accordance about this

entry point

Answer from Pascale

Have the overall group accordance about what

it is

Have the overall group accordance about what

it is

RESPONSIBLE

CONCLUSION

PRP
Christian

all negotiated advantages for both A line and F line were integrated in
the table

Christian

There will no new members to help

Christian

INcoming is all information which is been collected from outside

(mainly data subjects) and stored within EuroConsumers.
OUTgoing is all information which is been transferred to external
parties such as call centers, to fulfilment parties (for sending the
magazine), to a marketing agency for an e-mailing, to partners for the
member benefits (avantages ngocis), to partners for group purchase,
etc.. For that we decided that we would not make the inventory now,
but just add a column where the information could be given if information
is being exchanged without listing all of the information. E-mail used for
sending newletters is OUTgoing information.

MKT
Christian

MKT
Christian

Christian

Only the check boxes (opt in or out) for privacy policies are
in the scope

Pascale
Anja
Christian

we simple should add by the spontaneous that it is for those 3 options

(inbound call / mail/letter)

Christian

Putted into the document line DC-CNC-09

Answer given. It is not needed to put into the inventory document

I&S
Christian
Inventory Group

This kind of cases are considered Opt-in Passives

I&S
Christian
Inventory Group

Only PRP when having 3th parties involved could have an

"Internal and External use" of the data

STATUS

DONE

DONE

DONE

DONE

DONE

DONE

DONE

DONE

DONE

DONE

Separted Business Unit

Lobby and Press
DPC Actions

NOT FORGET
Personal Area
ASR 2.0
New Campaigns
...

http://www.condominiodeco.pt/
http://www.deco.proteste.pt/institucionalemedia/
These are lobby actions. Should they be taken into account?

When the personal area is launched what should we do?

When the ARS 2.0 is launched what should we do?
When new campaigns are launched, like smartvivio, what should we do?
Until when must we be upon this updating process?

Portugal
All countries
All countries

All
All
All
All

countries
countries
countries
countries