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Affino GDPR Client / Supplier Questionnaire

Frequently asked questions with answers for Affino’s GDPR compliancy.


Affino's GDPR Client Questionnaire

Your Affino GDPR Questions Answered

General Information

  • Company Name
    • Comrz Ltd trading as Affino
  • Questionnaire completed by
    • Markus Karlsson (CEO)
  • Date Completed
    • 25/5/2018


GDPR Awareness and Readiness

  • Is your organisation aware of the changes to data protection law under GDPR and how it will impact your business?
    • Yes, Affino have already made the relevant changes to our policies and procedures.
  • Have you undertaken formal gap analysis / an information audit against requirements under GDPR?
    • Yes
  • Have you initiated a project to achieve GDPR Compliance?
    • Yes
  • Do you expect to be compliant with GDPR by 25 May 2018?
    • Yes


Staff Involvement and Awareness

  • Have you appointed / will you appoint a Data Protection Officer?
    • Yes, Markus Karlsson (CEO)
  • Do you have a training program in place to ensure all relevant staff are aware of GDPR requirements prior to May 25 2018?
    • Yes


Data Governance

  • Have you created a record of your processing of personal data?
    • Yes
  • Please detail the personal data that your service or product collects, stores, processes or has access to.
    • Comrz Ltd trading as Affino processes and retains details within our CRM, including but not limited to, client name, company name, company contact details (address, email address and phone number/s), contact details (phone number/s and email address) of company personnel, and in some cases clients bank details (bank, sort code and account number).

    • Affino does not document or retain any credit card information.


Fair Processing and Privacy Notice

  • Do you intend to revise your Privacy Notice for GDPR?


Data Subject Rights

  • Do you have policies and procedures in place to comply with a data subject’s rights including their rights: to be informed; to access; to rectification; to erasure; to data portability; to object to direct marketing.
    • Yes


Data Transmission and Data Residency

  • Do you transfer personal data outside of the EEA?
    • No, no customer data is transited outside the EEA. Except where users have set up a public profile on a website which is then accessed internationally
  • If so, what steps have you taken to ensure GDPR Compliance?
    • N/A
  • Do you have a documented process for storing data and retaining it in line with GDPR requirements?
    • Yes. All data is stored on our secure servers, and protected with advanced security procedures and an array of defensive measures.
  • Has your organisation considered the GDPR Data Minimisation principle and reflected this in your relevant data retention policies?
    • Yes. Data held within our CRM database will be “flushed” automatically with data being deleted in as little as 4 months (starting in June 2018), and at a maximum of 6 years.
  • Do you encrypt personal data when you transfer it to 3rd parties?
    • Messages from our CRM are not routinely encrypted. Personal data is always encrypted when transmitted, and we only when send un-encryted personal data when requested to do so in writing.
  • Please describe how data that is transmitted is protected.
    • Encrypted


Data Breach

  • Have you documented your data breach notification procedures to meet GDPR requirements, and have all relevant staff been given adequate training in this?
    • Yes. A copy is available on-line here
  • Have you had any data breaches or large-scale data losses in the last 12 months?
    • No



Markus Karlsson Profile

Markus Karlsson, CEO | Founder, Affino

20 years of digital business experience with: Audi, BBC, Casio, Diesel, EMI, MasterCard, Rovio, UBM, UMG, and now Gill, Procurement Leaders, Briefing Media, Ocean Media, and IDG. Lead consultant for digital business transformation.




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