Privacy Policies GPDR
For all websites published by Gweva Group Corporation and Gweva First Corporation

Last updated May 22, 2018.

We've updated our Privacy Policies to reflect the European Union's (EU) new General Data Protection Regulation (GDPR) which was approved by the European Commission (EC) on 27 April 2016 and is law from 25 May 2018. 


Records Retention and Protection Policy



In its everyday business operations GWEVA GROUP CORPORATION collects and stores records of many types and in a variety of different formats. The relative importance and sensitivity of these records also varies and is subject to the organisation’s security classification scheme.

It is important that these records are protected from loss, destruction, falsification, unauthorised access and unauthorised release and a range of controls are used to ensure this, including backups, access control and encryption.

GWEVA GROUP CORPORATION also has a responsibility to ensure that it complies with all relevant legal, regulatory and contractual requirements in the collection, storage, retrieval and destruction of records. Of particular relevance is the European Union General Data Protection Regulation (GDPR) and its requirements concerning the storage and processing of personal data.

This control applies to all systems, people and processes that constitute the organisation’s information systems, including board members, directors, employees, suppliers and other third parties who have access to GWEVA GROUP CORPORATION systems.


The following documents are relevant to this policy:

  • Data Protection Policy

  • Data Protection Impact Assessment Process

  • Privacy Notice Procedure

  • Personal Data Analysis Procedure

Records Retention and Protection Policy:

This policy begins by establishing the main principles that must be adopted when considering record retention and protection. It then sets out the types of records held by GWEVA GROUP CORPORATION and their general requirements before discussing record protection, destruction and management.

General Principles

There are a number of key general principles that must be adopted when considering record retention and protection policy. These are:

  • Records must be held in compliance with all applicable legal, regulatory and contractual requirements

  • Records must not be held for any longer than required

  • The protection of records in terms of their confidentiality, integrity and availability must be in accordance with their security classification

  • Records must remain retrievable in line with business requirements at all times

  • Where appropriate, records containing personal data must be subject as soon as possible to techniques that prevent the identification of a living individual  

Record Types and Guidelines

In order to assist with the definition of guidelines for record retention and protection, records held by GWEVA GROUP CORPORATION are grouped into the categories listed in the table on the following page. For each of these categories, the required or recommended retention period and allowable storage media are also given, together with a reason for the recommendation or requirement.

Note that these are guidelines only and there may be specific circumstances where records need to be kept for a longer or shorter period of time. This should be decided on a case by case basis as part of the design of the information security elements of new or significantly changed processes and services.

Further information about records held by the organisation, including their security classifications and owners can be found in the Organisation-wide Personal Data Inventory.



Use of Cryptography

Where appropriate to the classification of information and the storage medium, cryptographic techniques must be used to ensure the confidentiality and integrity of records.

Care must be taken to ensure that encryption keys used to encrypt records are securely stored for the life of the relevant records and comply with the organisation’s policy on cryptography.

Media Selection

The choice of long term storage media must take into account the physical characteristics of the medium and the length of time it will be in use.

Where records are legally (or practically) required to be stored on paper, adequate precautions must be taken to ensure that environmental conditions remain suitable for the type of paper used. Where possible, backup copies of such records should be taken by methods such as scanning or microfiching. Regular checks must be made to assess the rate of deterioration of the paper and action taken to preserve the records if required.

For records stored on electronic media such as tape, similar precautions must be taken to ensure the longevity of the materials, including correct storage and copying onto more robust media if necessary. The ability to read the contents of the particular tape (or other similar media) format must be maintained by the keeping of a device capable of processing it. If this is impractical an external third party may be employed to convert the media onto an alternative format.

Record Retrieval

There is little point in retaining records if they are not able to be accessed in line with business or legal requirements. The choice and maintenance of record storage facilities must ensure that records can be retrieved in a usable format within an acceptable period of time. An appropriate balance should be struck between the cost of storage and the speed of retrieval so that the most likely circumstances are adequately catered for.

Record Destruction

Once records have reached the end of their life according to the defined policy, they must be securely destroyed in a manner that ensures that they can no longer be used. The destruction procedure must allow for the correct recording of the details of disposal which should be retained as evidence.

Record Review

The retention and storage of records must be subject to a regular review process carried out under the guidance of management to ensure that:

  • The policy on records retention and protection remains valid

  • Records are being retained according to the policy

  • Records are being securely disposed of when no longer required

  • Legal, regulatory and contractual requirements are being fulfilled

  • Processes for record retrieval are meeting business requirements

The results of these reviews must be recorded.



Data Protection Policy


In its everyday business operations GWEVA GROUP CORPORATION makes use of a variety of data about identifiable individuals, including data about:

  • Current, past and prospective employees

  • Customers

  • Users of its websites

  • Subscribers

  • Other stakeholders

In collecting and using this data, the organisation is subject to a variety of legislation controlling how such activities may be carried out and the safeguards that must be put in place to protect it.

The purpose of this policy is to set out the relevant legislation and to describe the steps GWEVA GROUP CORPORATION is taking to ensure that it complies with it.

This control applies to all systems, people and processes that constitute the organisation’s information systems, including board members, directors, employees, suppliers and other third parties who have access to GWEVA GROUP CORPORATION systems.

The following policies and procedures are relevant to this document:

  • Data Protection Impact Assessment Process

  • Personal Data Analysis Procedure

  • Legitimate Interest Assessment Procedure

  • Information Security Incident Response Procedure

  • GDPR Roles and Responsibilities

  • Records Retention and Protection Policy

Data Protection Policy

The General Data Protection Regulation

The General Data Protection Regulation 2016 (GDPR) is one of the most significant pieces of legislation affecting the way that GWEVA GROUP CORPORATION carries out its information processing activities. Significant fines are applicable if a breach is deemed to have occurred under the GDPR, which is designed to protect the personal data of citizens of the European Union. It is GWEVA GROUP CORPORATION ’s policy to ensure that our compliance with the GDPR and other relevant legislation is clear and demonstrable at all times.


There are a total of 26 definitions listed within the GDPR and it is not appropriate to reproduce them all here. However, the most fundamental definitions with respect to this policy are as follows:

Personal data is defined as:

any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;

‘processing’ means:

any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;

‘controller’ means:

the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law;

Principles Relating to Processing of Personal Data

There are a number of fundamental principles upon which the GDPR is based.

These are as follows:

  1. Personal data shall be:

(a) processed lawfully, fairly and in a transparent manner in relation to the data subject (‘lawfulness, fairness and transparency’);

(b) collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall, in accordance with Article 89(1), not be considered to be incompatible with the initial purposes (‘purpose limitation’);

(c) adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (‘data minimisation’);

(d) accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay (‘accuracy’);

(e) kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) subject to implementation of the appropriate technical and organisational measures required by this Regulation in order to safeguard the rights and freedoms of the data subject (‘storage limitation’);

(f) processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures (‘integrity and confidentiality’).

  1. The controller shall be responsible for, and be able to demonstrate compliance with, paragraph 1 (‘accountability’).

GWEVA GROUP CORPORATION will ensure that it complies with all of these principles both in the processing it currently carries out and as part of the introduction of new methods of processing such as new IT systems.


The data subject also has rights under the GDPR. These consist of:

  1. The right to be informed

  2. The right of access

  3. The right to rectification

  4. The right to erasure

  5. The right to restrict processing

  6. The right to data portability

  7. The right to object

  8. Rights in relation to automated decision making and profiling.

Each of these rights are supported by appropriate procedures within GWEVA GROUP CORPORATION . that allow the required action to be taken within the timescales stated in the GDPR.

These timescales are shown in Table 1.

Lawfulness of Processing

There are six alternative ways in which the lawfulness of a specific case of processing of personal data may be established under the GDPR. It is GWEVA GROUP CORPORATION policy to identify the appropriate basis for processing and to document it, in accordance with the Regulation. The options are described in brief in the following sections.


Unless it is necessary for a reason allowable in the GDPR, GWEVA GROUP CORPORATION will always obtain explicit consent from a data subject to collect and process their data. In case of children below the age of 16 (a lower age may be allowable in specific EU member states) parental consent will be obtained. Transparent information about our usage of their personal data will be provided to data subjects at the time that consent is obtained and their rights with regard to their data explained, such as the right to withdraw consent. This information will be provided in an accessible form, written in clear language and free of charge.

If the personal data are not obtained directly from the data subject then this information will be provided to the data subject within a reasonable period after the data are obtained and definitely within one month.

Performance of a Contract

Where the personal data collected and processed are required to fulfil a contract with the data subject, explicit consent is not required. This will often be the case where the contract cannot be completed without the personal data in question e.g. a delivery cannot be made without an address to deliver to.

​​​​​​​Legal Obligation

If the personal data is required to be collected and processed in order to comply with the law, then explicit consent is not required. This may be the case for some data related to employment and taxation for example, and for many areas addressed by the public sector.

​​​​​​​Vital Interests of the Data Subject

In a case where the personal data are required to protect the vital interests of the data subject or of another natural person, then this may be used as the lawful basis of the processing. GWEVA GROUP CORPORATION will retain reasonable, documented evidence that this is the case, whenever this reason is used as the lawful basis of the processing of personal data. As an example, this may be used in aspects of social care, particularly in the public sector.

​​​​​​​Task Carried Out in the Public Interest

Where GWEVA GROUP CORPORATION needs to perform a task that it believes is in the public interest or as part of an official duty then the data subject’s consent will not be requested. The assessment of the public interest or official duty will be documented and made available as evidence where required.

​​​​​​​Legitimate Interests

If the processing of specific personal data is in the legitimate interests of GWEVA GROUP CORPORATION and is judged not to affect the rights and freedoms of the data subject in a significant way, then this may be defined as the lawful reason for the processing. Again, the reasoning behind this view will be documented.

​​​​​​​Privacy by Design

GWEVA GROUP CORPORATION has adopted the principle of privacy by design and will ensure that the definition and planning of all new or significantly changed systems that collect or process personal data will be subject to due consideration of privacy issues, including the completion of one or more data protection impact assessments.

The data protection impact assessment will include:

  • Consideration of how personal data will be processed and for what purposes

  • Assessment of whether the proposed processing of personal data is both necessary and proportionate to the purpose(s)

  • Assessment of the risks to individuals in processing the personal data

  • What controls are necessary to address the identified risks and demonstrate compliance with legislation

Use of techniques such as data minimization and pseudonymisation will be considered where applicable and appropriate.

​​​​​​​Contracts Involving the Processing of Personal Data

GWEVA GROUP CORPORATION will ensure that all relationships it enters into that involve the processing of personal data are subject to a documented contract that includes the specific information and terms required by the GDPR. For more information, see the GDPR Controller-Processor Agreement Policy.

​​​​​​​International Transfers of Personal Data

Transfers of personal data outside the European Union will be carefully reviewed prior to the transfer taking place to ensure that they fall within the limits imposed by the GDPR. This depends partly on the European Commission’s judgement as to the adequacy of the safeguards for personal data applicable in the receiving country and this may change over time.

Intra-group international data transfers will be subject to legally binding agreements referred to as Binding Corporate Rules (BCR) which provide enforceable rights for data subjects.

​​​​​​​Data Protection Officer

A defined role of Data Protection Officer (DPO) is required under the GDPR if an organisation is a public authority, if it performs large scale monitoring or if it processes particularly sensitive types of data on a large scale. The DPO is required to have an appropriate level of knowledge and can either be an in-house resource or outsourced to an appropriate service provider.

Based on these criteria, GWEVA GROUP CORPORATION  does not require a Data Protection Officer to be appointed.

​​​​​​​​​​​​​​Breach Notification

It is GWEVA GROUP CORPORATION ’s policy to be fair and proportionate when considering the actions to be taken to inform affected parties regarding breaches of personal data. In line with the GDPR, where a breach is known to have occurred which is likely to result in a risk to the rights and freedoms of individuals, the relevant supervisory authority will be informed within 72 hours. This will be managed in accordance with our Information Security Incident Response Procedure which sets out the overall process of handling information security incidents.

Under the GDPR the relevant DPA has the authority to impose a range of fines of up to four percent of annual worldwide turnover or twenty million Euros, whichever is the higher, for infringements of the regulations.

​​​​​​​Addressing Compliance to the GDPR

The following actions are undertaken to ensure that GWEVA GROUP CORPORATION complies at all times with the accountability principle of the GDPR:

  • The legal basis for processing personal data is clear and unambiguous

  • A Data Protection Officer is appointed with specific responsibility for data protection in the organisation (if required)

  • All staff involved in handling personal data understand their responsibilities for following good data protection practice

  • Training in data protection has been provided to all staff

  • Rules regarding consent are followed

  • Routes are available to data subjects wishing to exercise their rights regarding personal data and such enquiries are handled effectively

  • Regular reviews of procedures involving personal data are carried out

  • Privacy by design is adopted for all new or changed systems and processes

  • The following documentation of processing activities is recorded:

    • Organisation name and relevant details

    • Purposes of the personal data processing

    • Categories of individuals and personal data processed

    • Categories of personal data recipients

    • Agreements and mechanisms for transfers of personal data to non-EU countries including details of controls in place

    • Personal data retention schedules

    • Relevant technical and organisational controls in place​

These actions are reviewed on a regular basis as part of the management process concerned with data protection.

Website Privacy Policy

This privacy policy tells you about the information we collect from you when you use our website. In collecting this information, we are acting as a data controller and, by law, we are required to provide you with information about us, about why and how we use your data, and about the rights you have over your data.

Who are we?

We are  GWEVA GROUP CORPORATION Our address is








You can contact us by post at the above address, by email at or by telephone on +1 302-543-2702

We are not required to have a data protection officer, so any enquiries about our use of your personal data should be addressed to the contact details above.

+1 302-543-2702

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