Manhattan’s commitment to GDPR readiness

What is “GDPR”?

• European regulation aimed at providing a single set of rules that protect European Union (EU) citizens personal data privacy
• Applies to EU and non-EU data controllers and processors who monitor the behavior of or offering goods or services to individuals located in the EU
• Goes into effect on May 25, 2018

Entitles the data subject to have the data controller erase his/her personal data, cease further dissemination of the data, and potentially have third parties halt processing of the data.

• You may need to delete customer data based on customer request.
• Manhattan Active™ Omni offers the required framework and APIs that enable you to meet your obligations under the GDPR.
• Customer data can also be erased by data sync from external applications which owns the customer master.
• Manhattan Active™ Omni also provides out of the box scripts to purge/archive customer data after a configurable period.

Consent must be clear and distinguishable from other matters and provided in an intelligible and easily accessible form, using clear and plain language. It must be as easy to withdraw consent as it is to give it.

• There are several ways that Manhattan Active™ Omni helps you comply with data protection and privacy regulations, including support for indicating do not call, email opt-out preferences. The rich extensibility framework offered by the solution can be leveraged to provide richer information in an intelligible and easily accessible form in your respective language.
• This can also be handled as part of a privacy notification message on your website.

Privacy by design calls for the inclusion of data protection from the onset of the designing of systems, rather than an addition. Hold and process only the data absolutely necessary for the completion of its duties (data minimisation), as well as limiting the access to personal data to those needing to act out the processing.

• Manhattan has security and privacy built into every layerof the application.
• Manhattan Active Omni ensures that there is no unintentional usage of customer data other than the intended purpose.
• Data access is controlled using appropriate user permissions available both at the individual user and user group level.
• There are measures taken both from R&D as well as Operations teams to perform Network, Static and Dynamic Vulnerability Scans to secure and protect customer data.
• As part of the Cloud Operations team we perform frequent Network Vulnerability Scans as well as additional security testing to protect customer data.

The right for data subjects to obtain from the data controller confirmation as to whether or not personal data concerning them is being processed, where and for what purpose. Further, the controller shall provide a copy of the personal data, free of charge, in an electronic format

• Manhattan Active™ Omni either updates the customer information (customer transactions/cases/master data) using our UIs or can receive updates from external systems to update the customer information.
• Manhattan maintains history of all updates made to customer data as part of its audit framework.
• Manhattan provides REST services and APIs at the individual data entity level and can work with the retailer to retrieve the required data and produce it in a clear, readable format.

The right for a data subject to receive the personal data concerning them, which they have previously provided in a 'commonly use and machine readable format' and have the right to transmit that data to another controller.

• Manhattan Active™ Omni provides APIs which can be used to extract customer data including personal data, transactions and social data stored within our application.
• Data can be extracted via both UI-driven and API-driven methods, including reports and report/dashboard APIs, data loader, REST APIs, and third-party ETL tools. Export formats include JSON, XML and CSV.

The establishment of a governance structure with roles and responsibilities. Keeping a detailed record of all data processing operations. Data protection impact assessments for high-risk processing operations. Where necessary, appoint a data protection officer.

• Manhattan mandates proper data transfer agreements for data transfer between EU and non-EU data centers.
• Manhattan currently offers direct meetings with Manhattan’s Data Protection Representatives and other security folks to discuss GDPR.
• These meetings would also include individuals familiar with how the Manhattan solutions are installed and used. Especially important is understanding where the data is stored (primary database of record) and how data moves through the system.
• Manhattan will work with you to develop a compliance plan which will include adding a strong legal and data policy framework for reconfiguration of the Manhattan solution or data interfaces.