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D-seal’s Data Ethics Considerations Framework

Industriens Hus, H.C. Andersens Boulevard 18, 1553 Copenhagen V

Reference: Requirement 8.1.1.1

Question 1

Has the company considered solutions to improve data ethics work? E.g., establishing a data ethics working group, awareness-building activities, culture of openness.

Not relevant

No considerations

Some considerations

Measures planned

Measures implemented

Continuous process established

Question 1

Has the company considered solutions to improve data ethics work? E.g., establishing a data ethics working group, awareness-building activities, culture of openness.

Not relevant

No considerations

Some considerations

Measures planned

Measures implemented

Continuous process established

Question 1

Has the company considered solutions to improve data ethics work? E.g., establishing a data ethics working group, awareness-building activities, culture of openness.

Not relevant

No considerations

Some considerations

Measures planned

Measures implemented

Continuous process established

Comments

  • We have made data ethics a cultural pillar with transparency as the main focus

  • We engage in open communication and encourage internal discussion across departments

  • All employees are covered by the policy, especially those involved in product development, design, analysis, AI, customer success, and marketing

  • Annual review of data ethics and management approval

Comments

  • We have made data ethics a cultural pillar with transparency as the main focus

  • We engage in open communication and encourage internal discussion across departments

  • All employees are covered by the policy, especially those involved in product development, design, analysis, AI, customer success, and marketing

  • Annual review of data ethics and management approval

Comments

  • We have made data ethics a cultural pillar with transparency as the main focus

  • We engage in open communication and encourage internal discussion across departments

  • All employees are covered by the policy, especially those involved in product development, design, analysis, AI, customer success, and marketing

  • Annual review of data ethics and management approval

Question 2

Has the company considered ongoing involvement of relevant stakeholders? E.g., to avoid unintended bias.

Not relevant

No considerations

Some considerations

Measures planned

Measures implemented

Continuous process established

Question 2

Has the company considered ongoing involvement of relevant stakeholders? E.g., to avoid unintended bias.

Not relevant

No considerations

Some considerations

Measures planned

Measures implemented

Continuous process established

Question 2

Has the company considered ongoing involvement of relevant stakeholders? E.g., to avoid unintended bias.

Not relevant

No considerations

Some considerations

Measures planned

Measures implemented

Continuous process established

Comments

  • We involve all relevant employee groups (development, design, analysis, marketing, customer success)

  • We encourage internal discussion across departments

  • Employees must speak up if a function or process seems ethically unclear or could unintentionally harm users

  • We treat all employees equally regardless of age, gender, skin color, or religion

Comments

  • We involve all relevant employee groups (development, design, analysis, marketing, customer success)

  • We encourage internal discussion across departments

  • Employees must speak up if a function or process seems ethically unclear or could unintentionally harm users

  • We treat all employees equally regardless of age, gender, skin color, or religion

Comments

  • We involve all relevant employee groups (development, design, analysis, marketing, customer success)

  • We encourage internal discussion across departments

  • Employees must speak up if a function or process seems ethically unclear or could unintentionally harm users

  • We treat all employees equally regardless of age, gender, skin color, or religion

Question 3

Has the company considered the consequences associated with influencing user behavior? E.g., counteracting addiction, overconsumption, bullying.

Not relevant

No considerations

Some considerations

Measures planned

Measures implemented

Continuous process established

Question 3

Has the company considered the consequences associated with influencing user behavior? E.g., counteracting addiction, overconsumption, bullying.

Not relevant

No considerations

Some considerations

Measures planned

Measures implemented

Continuous process established

Question 3

Has the company considered the consequences associated with influencing user behavior? E.g., counteracting addiction, overconsumption, bullying.

Not relevant

No considerations

Some considerations

Measures planned

Measures implemented

Continuous process established

Comments

  • Our products (EasyScep, EasyRadius SaaS) are B2B IT security solutions

  • We do not influence user behavior in ways that can lead to addiction, overconsumption, or bullying

  • We do not use cameras or scanners

  • Our purpose is to deliver security solutions, not to manipulate user behavior






Comments

  • Our products (EasyScep, EasyRadius SaaS) are B2B IT security solutions

  • We do not influence user behavior in ways that can lead to addiction, overconsumption, or bullying

  • We do not use cameras or scanners

  • Our purpose is to deliver security solutions, not to manipulate user behavior






Comments

  • Our products (EasyScep, EasyRadius SaaS) are B2B IT security solutions

  • We do not influence user behavior in ways that can lead to addiction, overconsumption, or bullying

  • We do not use cameras or scanners

  • Our purpose is to deliver security solutions, not to manipulate user behavior






Question 4

If the company influences user behavior, has the company considered how this can be made more transparent and give the user more control?

Not relevant

No considerations

Some considerations

Measures planned

Measures implemented

Continuous process established

Question 4

If the company influences user behavior, has the company considered how this can be made more transparent and give the user more control?

Not relevant

No considerations

Some considerations

Measures planned

Measures implemented

Continuous process established

Question 4

If the company influences user behavior, has the company considered how this can be made more transparent and give the user more control?

Not relevant

No considerations

Some considerations

Measures planned

Measures implemented

Continuous process established

Comments

  • As mentioned in question 3, we do not influence user behavior in problematic ways

  • We focus on transparency in our data processing generally

  • Users have full control over their data through our user rights system

Comments

  • As mentioned in question 3, we do not influence user behavior in problematic ways

  • We focus on transparency in our data processing generally

  • Users have full control over their data through our user rights system

Comments

  • As mentioned in question 3, we do not influence user behavior in problematic ways

  • We focus on transparency in our data processing generally

  • Users have full control over their data through our user rights system

Question 5

Has the company considered how user rights are prioritized over commercial or institutional interests?

Not relevant

No considerations

Some considerations

Measures planned

Measures implemented

Continuous process established

Question 5

Has the company considered how user rights are prioritized over commercial or institutional interests?

Not relevant

No considerations

Some considerations

Measures planned

Measures implemented

Continuous process established

Question 5

Has the company considered how user rights are prioritized over commercial or institutional interests?

Not relevant

No considerations

Some considerations

Measures planned

Measures implemented

Continuous process established

Comments

  • “Users own their data” is our first key principle

  • We always treat user data as owned by them, not by us

  • We function as data processor and do not sell or misuse user data

  • We give users meaningful control – real choices, not just legal compliance

  • As customers, there are no restrictions on using our products

Comments

  • “Users own their data” is our first key principle

  • We always treat user data as owned by them, not by us

  • We function as data processor and do not sell or misuse user data

  • We give users meaningful control – real choices, not just legal compliance

  • As customers, there are no restrictions on using our products

Comments

  • “Users own their data” is our first key principle

  • We always treat user data as owned by them, not by us

  • We function as data processor and do not sell or misuse user data

  • We give users meaningful control – real choices, not just legal compliance

  • As customers, there are no restrictions on using our products

Question 6

Has the company considered how users get the most possible value from the data collected?

Not relevant

No considerations

Some considerations

Measures planned

Measures implemented

Continuous process established

Question 6

Has the company considered how users get the most possible value from the data collected?

Not relevant

No considerations

Some considerations

Measures planned

Measures implemented

Continuous process established

Question 6

Has the company considered how users get the most possible value from the data collected?

Not relevant

No considerations

Some considerations

Measures planned

Measures implemented

Continuous process established

Comments

  • We give users oversight and the ability to manage their data in the system

  • Users can access their complete data, download data in usable formats

  • We use clear language to explain what specific data we collect and why

  • Data is only shared with clients in anonymized and aggregated form

Comments

  • We give users oversight and the ability to manage their data in the system

  • Users can access their complete data, download data in usable formats

  • We use clear language to explain what specific data we collect and why

  • Data is only shared with clients in anonymized and aggregated form

Comments

  • We give users oversight and the ability to manage their data in the system

  • Users can access their complete data, download data in usable formats

  • We use clear language to explain what specific data we collect and why

  • Data is only shared with clients in anonymized and aggregated form

Question 7

Has the company considered how to avoid unintended consequences? E.g., surveillance, misuse, spread of misinformation, or similar.

Not relevant

No considerations

Some considerations

Measures planned

Measures implemented

Continuous process established

Question 7

Has the company considered how to avoid unintended consequences? E.g., surveillance, misuse, spread of misinformation, or similar.

Not relevant

No considerations

Some considerations

Measures planned

Measures implemented

Continuous process established

Question 7

Has the company considered how to avoid unintended consequences? E.g., surveillance, misuse, spread of misinformation, or similar.

Not relevant

No considerations

Some considerations

Measures planned

Measures implemented

Continuous process established

Comments

  • We do not use cameras or scanners to avoid surveillance problems

  • We function as data processor and do not sell or misuse user data

  • Data is only shared with clients in anonymized and aggregated form

  • We have implemented protective measures in our system design

  • Employees are encouraged to speak up about ethical concerns

Comments

  • We do not use cameras or scanners to avoid surveillance problems

  • We function as data processor and do not sell or misuse user data

  • Data is only shared with clients in anonymized and aggregated form

  • We have implemented protective measures in our system design

  • Employees are encouraged to speak up about ethical concerns

Comments

  • We do not use cameras or scanners to avoid surveillance problems

  • We function as data processor and do not sell or misuse user data

  • Data is only shared with clients in anonymized and aggregated form

  • We have implemented protective measures in our system design

  • Employees are encouraged to speak up about ethical concerns

Question 8

Has the company considered how the company can protect special target groups? E.g., children and youth or social groups with special challenges.

Not relevant

No considerations

Some considerations

Measures planned

Measures implemented

Continuous process established

Question 8

Has the company considered how the company can protect special target groups? E.g., children and youth or social groups with special challenges.

Not relevant

No considerations

Some considerations

Measures planned

Measures implemented

Continuous process established

Question 8

Has the company considered how the company can protect special target groups? E.g., children and youth or social groups with special challenges.

Not relevant

No considerations

Some considerations

Measures planned

Measures implemented

Continuous process established

Comments

  • Our products are B2B IT security solutions aimed at companies

  • We do not directly serve children or particularly vulnerable population groups

  • Our customer base consists of companies and organizations

  • Protection of vulnerable groups is not relevant to our business model

Comments

  • Our products are B2B IT security solutions aimed at companies

  • We do not directly serve children or particularly vulnerable population groups

  • Our customer base consists of companies and organizations

  • Protection of vulnerable groups is not relevant to our business model

Comments

  • Our products are B2B IT security solutions aimed at companies

  • We do not directly serve children or particularly vulnerable population groups

  • Our customer base consists of companies and organizations

  • Protection of vulnerable groups is not relevant to our business model

Question 9

Has the company considered whether data collection and solutions/products can limit citizens’ rights?

Not relevant

No considerations

Some considerations

Measures planned

Measures implemented

Continuous process established

Question 9

Has the company considered whether data collection and solutions/products can limit citizens’ rights?

Not relevant

No considerations

Some considerations

Measures planned

Measures implemented

Continuous process established

Question 9

Has the company considered whether data collection and solutions/products can limit citizens’ rights?

Not relevant

No considerations

Some considerations

Measures planned

Measures implemented

Continuous process established

Comments

  • As customers, there are no restrictions on using our products

  • We have flexible working conditions and adapt to employees’ needs

  • Users have full control: access, download, correction, deletion of their data

  • We prioritize user rights over commercial interests

  • Our systems are designed to strengthen, not limit, users’ control over their data

Comments

  • As customers, there are no restrictions on using our products

  • We have flexible working conditions and adapt to employees’ needs

  • Users have full control: access, download, correction, deletion of their data

  • We prioritize user rights over commercial interests

  • Our systems are designed to strengthen, not limit, users’ control over their data

Comments

  • As customers, there are no restrictions on using our products

  • We have flexible working conditions and adapt to employees’ needs

  • Users have full control: access, download, correction, deletion of their data

  • We prioritize user rights over commercial interests

  • Our systems are designed to strengthen, not limit, users’ control over their data

Question 9

Has the company considered whether data collection and solutions/products can limit citizens’ rights?

Not relevant

No considerations

Some considerations

Measures planned

Measures implemented

Continuous process established

Question 9

Has the company considered whether data collection and solutions/products can limit citizens’ rights?

Not relevant

No considerations

Some considerations

Measures planned

Measures implemented

Continuous process established

Question 9

Has the company considered whether data collection and solutions/products can limit citizens’ rights?

Not relevant

No considerations

Some considerations

Measures planned

Measures implemented

Continuous process established

Comments

  • As customers, there are no restrictions on using our products

  • We have flexible working conditions and adapt to employees’ needs

  • Users have full control: access, download, correction, deletion of their data

  • We prioritize user rights over commercial interests

  • Our systems are designed to strengthen, not limit, users’ control over their data

Comments

  • As customers, there are no restrictions on using our products

  • We have flexible working conditions and adapt to employees’ needs

  • Users have full control: access, download, correction, deletion of their data

  • We prioritize user rights over commercial interests

  • Our systems are designed to strengthen, not limit, users’ control over their data

Comments

  • As customers, there are no restrictions on using our products

  • We have flexible working conditions and adapt to employees’ needs

  • Users have full control: access, download, correction, deletion of their data

  • We prioritize user rights over commercial interests

  • Our systems are designed to strengthen, not limit, users’ control over their data

Question 10

Has the company considered whether they can avoid reinforcing social and ethical problems? E.g., inequality, exposure of population groups and segments, or that a solution can only be used by certain users.

Not relevant

No considerations

Some considerations

Measures planned

Measures implemented

Continuous process established

Question 10

Has the company considered whether they can avoid reinforcing social and ethical problems? E.g., inequality, exposure of population groups and segments, or that a solution can only be used by certain users.

Not relevant

No considerations

Some considerations

Measures planned

Measures implemented

Continuous process established

Question 10

Has the company considered whether they can avoid reinforcing social and ethical problems? E.g., inequality, exposure of population groups and segments, or that a solution can only be used by certain users.

Not relevant

No considerations

Some considerations

Measures planned

Measures implemented

Continuous process established

Comments

  • We do not develop special logic that takes into account age, gender, skin color, or religion

  • Everyone in the company is treated fairly and equally, regardless of age, gender, skin color, or religion

  • Developers must not create algorithms to treat users differently based on demographics

  • We focus on equal access to our products and services

  • Our design principles promote equality rather than discrimination

Comments

  • We do not develop special logic that takes into account age, gender, skin color, or religion

  • Everyone in the company is treated fairly and equally, regardless of age, gender, skin color, or religion

  • Developers must not create algorithms to treat users differently based on demographics

  • We focus on equal access to our products and services

  • Our design principles promote equality rather than discrimination

Comments

  • We do not develop special logic that takes into account age, gender, skin color, or religion

  • Everyone in the company is treated fairly and equally, regardless of age, gender, skin color, or religion

  • Developers must not create algorithms to treat users differently based on demographics

  • We focus on equal access to our products and services

  • Our design principles promote equality rather than discrimination

Question 11

Does the company communicate its privacy-by-design strategies to its users?

Not relevant

No considerations

Some considerations

Measures planned

Measures implemented

Continuous process established

Question 11

Does the company communicate its privacy-by-design strategies to its users?

Not relevant

No considerations

Some considerations

Measures planned

Measures implemented

Continuous process established

Question 11

Does the company communicate its privacy-by-design strategies to its users?

Not relevant

No considerations

Some considerations

Measures planned

Measures implemented

Continuous process established

Comments

  • We communicate these during onboarding and through signage

  • We work to improve our messaging and support customers in doing the same

  • We use clear language to explain: what data we collect, why we need each type of data, how long we store it, who else can access it, how we protect it

  • We are transparent about our role as data processor

  • We give users clear, accessible ways to control their data

Comments

  • We communicate these during onboarding and through signage

  • We work to improve our messaging and support customers in doing the same

  • We use clear language to explain: what data we collect, why we need each type of data, how long we store it, who else can access it, how we protect it

  • We are transparent about our role as data processor

  • We give users clear, accessible ways to control their data

Comments

  • We communicate these during onboarding and through signage

  • We work to improve our messaging and support customers in doing the same

  • We use clear language to explain: what data we collect, why we need each type of data, how long we store it, who else can access it, how we protect it

  • We are transparent about our role as data processor

  • We give users clear, accessible ways to control their data