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Santa is a trading name of St Nicholas, located in the North Pole.
Santa keeps a list of every boy and girl to determine whether they are entitled to delivery on Christmas Eve.
He uses global surveillance to monitor whether you are naughty or nice. Santa uses automated decision making to put you on the nice list. A full set of the criteria can be obtained from your nearest parent.
Santa keeps your name, age and address, as well as an up to date note of whether you are naughty or nice.
The information about you is kept in the North Pole both manually and on computers located there. Your information is covered by the Elf Shield arrangement negotiated with the EU. Santa has an Elf Shield.
Santa shares this data with all the elves at the North Pole. They are all third- party data processors. They use this information to manufacture, label and load the correct toys ready for delivery on the correct day. The Elves are all under contracts of confidentiality. In thousands of years of operation, there has never been a data breach or a hack, though occasionally children have worked out in advance which presents they are getting. Investigations have revealed this is usually a data breach by the parents. The Elves have also been retrained to Elf Shield data privacy standards.
Santa shares data with the Tooth Fairy and the Easter Bunny in order to cross-check the children are still in the same place. So many children move house each year. We do this to avoid delivering to the wrong address. Both the Tooth Fairy and the Easter Bunny share Santa’s data facility and also have the Elf Shield for data privacy.
Santa is processing this data on the basis that he has a legitimate interest in doing so. He has assessed the data privacy impact and assessed it as low despite the fact he is holding information on children. He also processes some data on the basis of consent. The Elves have distributed consent forms to the parents. They should be completed in the normal way and then sent up the chimney.
Santa does not retain records for grown-ups. Santa’s data retention policy is to keep the data as long as he is responsible for assessing the child for the naughty or nice list and then delivering a present where the child is designated nice.
If you want to see what Santa holds on the list about you (if you are a child) or about your child, you should contact ElfShield@NorthPole.glob.
You can request to be removed from the nice list but this may result in the non-delivery of presents.
Wishing you all the season’s greetings from everyone at KoffeeKlatch.