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In 2018, one of the main challenges for the entire

company was the preparation for the new European

Regulation (EU) 2016/679, concerning the protection of

individuals with regard to the processing of their personal

data – GDPR (General Data Protection Regulation), which

came into force. The topic is gaining increasing popularity

and importance for all interested parties. Our company

has always strictly complied with the requirements of the

national legislation on the collection and processing of

personal data, works closely with the competent body –

the Commission for Personal Data Protection (CPDP), and

continues to make the necessary efforts to protect the

data of all its clients and partners.

The new regulation required a review and change of many

internal processes, policies, procedures and systems,

as well as of relationships with external organizations

involved in the processing of personal data.

The alignment with Regulation (EU) 2016/679 affected the

activities not only of all directorates having direct contact

with the company’s clients such as Customer Service,

Sales, Technical Directorate, but also almost all supporting

functions such as Finance, Customer Experience, Marketing

Communications, Corporate Communications, etc. Each of

them reviewed their processes and, together with the

Data Protection Officer, made the necessary adjustments

to meet the new European requirements. The process of

preparing for the entry into force of the Regulation began

in 2017 and in 2018 each employee of the company went

through two trainings on the topic – one common for the

entire organization affecting the principles of GDPR, and

one specialized on changes in his/her specific function.

Both trainings were completed with mandatory tests to

verify the knowledge that all employees successfully

passed.

Revision and change also underwent the processes of

the Human Resources Directorate, especially in relation to

the processing of data for job applicants and employees.

They also achieved a high level of compliance with the

requirements of Regulation (EU) 2016/679.

For the reporting period, only 20 records have been filed

in CPDP for complaints from our customers and there are

no established confirmed cases of theft or loss of data of

a client.

4.4.2.

Regulation and Management of Personal Data

Maintaining honest and open communication with

employees is one of the main priorities of the company’s

top management. Board members stay firmly behind

the belief that employees in an organization should be

its ambassadors and promote it in their circle. And this

can only happen if they feel informed about everything

current and important in a timely manner.

Therefore, in 2018, we built up the already established

internal campaigns ‘For VIVACOM with Atanas Dobrev’

and Tech Talk with the Chief Technical Officer, as we held

meetings with the directors of two other departments

– Marketing and Sales. The goal of the events was

managers of various functions to present in more detail

the work, achievements and plans for the development

of their units.

The Marketing Directorate colleagues presented the

exciting activities related to ad creation and positioning of

the VIVACOM brand, the challenging task of keeping the

company's official website always up-to-date and increase

customer satisfaction, as well as the responsibility to

create customer-oriented tariff plans.

The representatives of Sales Directorate shared how

they manage to attract new customers and to keep their

current ones satisfied with a personal approach to the

needs of each client and assistance in choosing among

the variety of telecom services and devices.

Each meeting was streamed live online on the company's

internal portal and had an average viewing rate of about

2,000 people, and the 100-person auditorium hall was

filled to capacity.

A similar type of initiative was also held on a smaller

scale – especially for the needs of our IT unit. Its main

goal was the managers of the department to introduce

the key projects and to get concrete proposals from their

employees to increase efficiency into the entire structure.

These meetings were also streamed live online so that

maximum number of people could join.

As a telecommunication company, it is extremely

important for us to maintain an open dialogue in society

about the opportunities and the dangers of the Internet,

especially for the vulnerable child audience. We believe

that all users must be well informed on this subject in

order to be able to protect both themselves and the

children around them.

That is why we used the festive mood around June 1st

(Children's Day) to bring our employees' attention to the

current and important topic of safe Internet. The campaign

had two parts. The first one was a public lecture for adults

with useful tips on what to watch out for online and how

to protect children around them. The second part was a

special event for the employees' children, in which the

various ‘faces’ of the network were presented through

entertaining presentations with game elements. Partners

of the initiative were the Directorate of Computer Crimes

at the Directorate-General for Combating Organized

Crime, Safer Internet Center, Bulbera safe Internet surfing

application, Cartoon Network and Buba Play. The event

was attended by more than 100 children.

4.4.3.

Internal Employee Initiatives

Georgi Sredkov,

Corporate Information Protection Manager at

VIVACOM:

‘In accordance with the new data protection rules that came into force with

Regulation (EU) 2016/679 (GDPR), significant work was done in 2018 on all

aspects: administrative, process organizational, legal and technological. True to the

principles of transparent and lawful processing of personal data and maintenance

of accountability, during the year we introduced appropriate technical and

organizational measures, trainings and courses, with which BTC consistently

follows the path of building and maintaining a comprehensive data protection

management system.’

ANNUALREPORT

2018

INTEGRATED

4.

PERFORMANCE

4.4.

Honest

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