On May 25, 2018, the European Union (the “EU”) implemented a new data privacy and protection regulation, called the General Data Protection Regulation (the “GDPR”). This new regulation aims to standardize data protection laws across the EU and also lay down standards to be observed worldwide while processing of personal data originating in the EU; The GDPR also has a strong emphasis on affording individuals stronger, more consistent rights to access and control their personal information.
At Blazeclan, we take compliance of data privacy and security regulations very seriously. For the GDPR, we are working diligently to ensure that we are compliant with the rules laid out by the law and provide product functionality and mould our services to enable us to remain compliant. In the following sections, we have outlined our approach to comply with the GDPR.
Blazeclan GDPR Compliance
Blazeclan group is a provider of cloud based services which include advisory services, cloud migration and deployment solutions, cloud native applications, data analytics and other cloud based products. Blazeclan has a global presence having its offices at Pune, Mumbai, Singapore, Malaysia, Europe, USA, Australia and Canada.
Our website is used and explored by our clients (existing and prospective), and through the same we at Blazeclan process certain amount of personal data of our clients (existing and prospective) in the capacity of a Data Controller. While providing our solutions and services we assume the role of a Data Processor for our clients, who provide us personal information for the purposes of our offerings.
Risk Assessment
We have performed a company-wide information discovery exercise to identify and assess what personal information we hold, where it comes from, how and why it is processed, and to whom it is disclosed.
Data Subject Consent
As a Data Controller, Blazeclan has updated its Privacy Policies, Cookies Policy and Disclaimer for the usage of the Cookies in as per the requirements of GDPR on its website www.blazeclan.com.
As a Data Processor, we execute contracts required under the GDPR with our clients (who are the Data Controllers) and process the personal information as per their directions and in accordance with the GDPR where applicable. Additionally, we implement technical and organizational security measures to ensure compliances.
Transfer of Data Outside EU
Blazeclan has in place an article 28 GDPR-compliant data processing addendum including the EU Model Clauses to ensure an appropriate legal basis for data transfers outside the EU.
Data Retention & Erasure
We have formulated a data retention policy and schedule to ensure that we comply with the ‘data minimization’ and ‘storage limitation’ principles and that personal information is stored, archived, and destroyed in accordance with the GDPR.
Record Keeping as per the GDPR
According to Article 30 of the GDPR, each processor and controller’s representative needs to maintain a record of all activities pertaining to the processing of personal information in such an organization. Blazeclan maintains a controller processing record as required under Article 30(1) of the GDPR as well as processor processing record as required under Article 30(2) of the GDPR.
Data Breach and Mitigation Process
The GDPR has stipulated measures and notifications that must be made upon discovery of a data security breach. Blazeclan has put in place internal measures to minimize the risk of any data security breach happening. However, in the unlikely event of any such breach happening, Blazeclan intends to honour its responsibilities as laid down under the GDPR, which includes notifying in a timely manner, its customers, and the supervisory authorities (if Blazeclan is the Data Controller).
Compliance Team
We have a team of leaders who head our GDPR compliance initiative and ensures that the processes flow down to each individual within the organization who handles data governed by the GDPR; should you require any clarification on any aspect of Blazeclan’s compliance efforts please contact our team at gdprcompliance@blazeclan.com.
Blazeclan Promise on GDPR
At Blazeclan, maintaining the security, integrity, safety and confidentiality of personal data in our business is one of the highest priorities. Blazeclan has already taken adequate measures to ensure that we fulfil our promise of being fully compliant with GDPR! In case you have any queries, please feel free to reach us at gdprcompliance@blazeclan.com.
Corporate Social Responsibility (CSR) Policy
Overview
At the outset, CSR activities at Blazeclan Technologies Private Limited (hereinafter referred to as “the Company”) is already in existence for the benefit of the employees and their immediate family members in the areas of extending loan to employees, participation at festivals and best worker award etc.
It is recognized that integrating social, environmental and ethical responsibilities into the governance of businesses ensures the long term success, competitiveness and sustainability.
Further, CSR makes a business sense as companies with effective CSR, have image of socially responsible companies, achieve sustainable growth in their operations in the long run and their products and services are preferred by the customers.
The CSR policy is being formulated to align its practices with the requirements of the Companies Act, 2013 (“the Act”) and the Companies (Corporate Social Responsibility Policy) Rules, 2014 (“the Rules”) made there under.
Objective
The main objective of CSR policy is to make CSR a key business process for sustainable development of the society. The Company will act as a good corporate citizen and aims at supplementing the role of Government in enhancing the welfare measures of the society within the framework of its policy.
Main focus areas
The CSR activities shall be undertaken by the Company, as stated in this Policy, as projects or programs or activities (either new or ongoing), excluding activities undertaken in pursuance of its normal course of business.
The CSR activities which are exclusively for the benefit of the Company employees or their family members shall not be considered as CSR activity.
The CSR activities shall be undertaken in locations within India. The Company shall give preference to the local area or areas around it where it operates, for spending the amount earmarked for CSR activities.
There are several areas having scopes, the Company is committed to involve in specific areas which prioritizing society needs. The main focus areas will be:
- Promoting education: Schools in need to have books and stationeries
- Sanitation: Water filters, health and hygiene items to charity homes for old age, women and orphans.
- Swachh Bharat- Clean India Campaign: Cleaning public parks, schools and public places for healthy living
- Restoration of school buildings: By painting school building walls and surroundings, restoring the schools
- Armed forces: Through ‘Flag Day Fund’, helping armed force veterans and their families.
- Promoting sports: Sponsoring school teams and children to participate in national level games, coaching material arts.
- Disaster Relief Fund: Fund Contribution to natural level disasters and calamities
- Medical aids: Physiotherapy, medical equipment treatment aids to needy.
In addition to above, the Company may from time to time undertake any project, program and activity in one or more of the following areas:
- Eradicating hunger, poverty and malnutrition, promoting preventive health care and sanitation and making available safe drinking water;
- Promoting education, including special education and employment enhancing vocation skills especially among children, women, elderly, and the differently abled and livelihood enhancement projects;
- Promoting gender equality, empowering women, setting up homes and hostels for women and orphans; setting up old age homes, day care centres and such other facilities for senior citizens and measures for reducing inequalities faced by socially and economically backward groups;
- Ensuring environmental sustainability, ecological balance, protection of flora and fauna, animal welfare, agroforestry, conservation of natural resources and maintaining quality of soil, air and water;
- Protection of national heritage, art and culture including restoration of buildings and sites of historical importance and works of art; setting up public libraries; promotion and development of traditional arts and handicrafts:
- Measures for the benefit of armed forces veterans, war widows and their dependents;
- Training to promote rural sports, nationally recognised sports, paralympic sports and Olympic sports;
- Contribution to the Prime Minister’s National Relief Fund or any other fund set up by the Central Government for socio-economic development and relief and welfare of the Scheduled Castes, the Scheduled Tribes, other backward classes, minorities and women;
- Contributions or funds provided to technology incubators located within academic institutions which are approved by the Central Government
- Rural development projects;
- Any other measures with the approval of Board of Directors on the recommendation of CSR Committee subject to the provisions of Section 135 of Companies Act, 2013 and rules made there-under.
The Company may update the above list as per Section 135 and Schedule VII (Activities which may be included by Companies in their Corporate Social Responsibility Policy) of the Act as amended from time to time.
Functioning of CSR activities
CSR Committee
The Board of Directors of the Company in their board meeting dated 20thMay, 2020 constituted a committee called the “Corporate Responsibility Committee” (CSR Committee) in accordance with the provisions of the Act and Rules made thereunder, The CSR Committee at any given point of time will consist of 2 (Two) Directors or such other numbers of Directors as the board of directors of the Company may determine from time to time. The board of directors may change the composition of the CSR Committee from time to time in such manner as it thinks fit. Members of the CSR Committee may be replaced by any other members of the Board.\
CSR Spending
- The Committee shall endeavour that the Company spends in every financial year, at least 2 % (two per cent) of its average net profit made during the three immediately financial years or where it has not completed the period of three financial years since its incorporation, during such immediately preceding financial years, in pursuance of the CSR policy.
- CSR expenditure shall include all expenditure including contribution to corpus, or on projects or programs relating CSR activities approved by the board of directors of the Company on the recommendation of its CSR Committee, but does not include any expenditure on an item not is conformity or not in line with the activities which fall within the areas or subject in Schedule VII of the Act.
- The CSR projects or programs or activities undertaken in India only shall amount to CSR expenditure.
- Tax treatment of CSR spent will be in accordance with the Income Tax Act as may be notified by CBDT.
Roles and responsibilities
The CSR Committee shall have inter alia the following roles, powers and responsibility:
- Formulate and recommend the CSR policy and any amendments therein to the board of directors of the Company which shall indicate the activities to be undertaken by the Company in areas or subject specified in Schedule VII of the Act;
- Develop and approve CSR projects, programs and activities to be undertaken from time to time either directly by the Company or through other entities;
- Determine modalities of execution of such CSR projects, programs and activities in consultation with the board of directors of the Company;
- Undertake all necessary steps to implement the CSR activities;
- Authorize and approve CSR expenditure from time to time subject to the limits approved by the board of directors of the Company and in accordance with the Act;
- Monitor the CSR activities in accordance with the Act;
- Carry out such acts, deeds, matters and things as may be required in connection with aforesaid matters and for any matter in pursuance of the CSR policy of the Company;
- Recommend to the Board of Directors of the Company the amount of expenditure to be incurred towards CSR;
- Monitor the CSR policy of the Company from time to time and
- To perform such functions as may be entrusted by the board of directors from time to time.
Identification of activities/projects
Out of main focus area CSR activities, the Committee shall decide which activity/project should be given priority for the respective financial year. While arriving at the decision of the activity to be undertaken for the respective year, the Committee shall analyse the basic need of the community/ area in which the Organisation operates or at the place where its registered office is situated. The Committee shall record its findings and prioritised the CSR activities.
Implementation process
After prioritizing the activity the Committee shall finalise the detail implementation project/programme, including planning for expenses against the total budget allocated for CSR activities.
Information dissemination
The Company’s engagement in this domain is disseminated on its website, annual reports and its house journals as and when deem fit.
Management Commitment
Our Board of Directors, our Management and all of our employees subscribe to the philosophy of compassionate care. We believe and act on an ethos of generosity and compassion, characterised by a willingness to build a society that works for everyone. This is the cornerstone of our CSR policy.
Update
CSR Committee of the Company will review the policy from time to time based on the changing needs and aspirations of the target beneficiaries and make suitable modifications as may be necessary.
Compliance with Companies Act, 2013
The provisions of the Section 135 of the Companies Act, 2013 of CSR was applicable to the Company and the Company was required to spend Rs. 5,82,232 during the year 2018-19. However, the Company came to know about applicability of the provisions of the Section 135 of the Companies Act, 2013 during the year 2020-21 and formed the Corporate Social Responsibility Committee in the Company’s board meeting held on 20thMay, 2020 The Company is in the process of computing and regularizing this as per compliance by 31st March 2021.
