Due to the nature of services provided by us we acquire a lot of sensitive data every day. To fully protect the data of each customer, the companies from Polsat Plus Group implemented the numerous rules defined in relevant policies and plans: Security Policy, Information Security Policy, Personal Data Security Policy, ICT Security Policy and ICT Security System Development Plan.

We respect legal regulations

In 2020, following the monitoring of the IPLA on-demand media service, which was conducted by KRRiT (National Broadcasting Council), we received 2 notices from KRRiT. In the notice dated 5 October 2020 Cyfrowy Polsat was requested to discontinue the activities infringing upon the provisions of Art. 46 e of the Broadcasting Act (incorrect marking an audiovisual material), while the notice dated 22 October 2020 requested that we discontinue the activities infringing upon the provisions of Art. 47 e, item 1 of the Broadcasting Act (use of insufficient technical safeguards). None of these notices ended with any proceedings being instituted against Cyfrowy Polsat.

Polkomtel received 3 complaints regarding spontaneous combustion of equipment. Two of the complaints were rejected by handset manufacturers. One complaint was accepted by the manufacturer of a router, however the reasons of the incident were not determined.

In 2020 at Polkomtel:

• 12 complaints related to personal data processing. In the case of 2 of these complaints the President of the Personal Data Protection Office (PUODO) refused to accept the requests from the complaining parties. As regards one of the cases, the President of the Personal Data Protection Office dismissed the case. In 6 other cases the Personal Data Protection Office (UODO) asked the Company to provide additional explanations. As of the date, the UODO did not respond to the explanations provided by the Company,
• As regards 3 proceedings initiated in the years 2018-2019, the Personal Data Protection Office asked the Company to provide additional explanations. As of the date of the report, the Office has not commented on the explanations submitted by the Company,
• We received 4 decisions regarding the Office’s proceedings from 2019 (in two cases the President of the Personal Data Protection Office dismissed the cases while in two other cases he refused to accept the requests from the complaining parties),
• In connection with the verification proceedings conducted by the Personal Data Protection Office regarding the implementation of the administrative decision issued by the General Inspector of Personal Data Protection (GIODO) in 2015 which concerned deletion of the copies of the documents collected when concluding subscriber contracts for telecommunication services, UODO filed two requests to the Company for being provided with additional evidence. The Company responded to the requests and sent to the President of the Personal Data Protection Office the protocol which confirmed the execution of the administrative decision. In January the President of the Personal Data Protection Office sent to the Company the information confirming end of the proceedings

Moreover, Polkomtel received 29 requests from the Personal Data Protection Office regarding reported cases of breach of personal data protection.

In 2020 the following notices were sent by the Personal Data Protection Office (UODO) to Cyfrowy Polsat S.A.:

• 4 complaints regarding personal data processing. In the case of 3 of these complaints UODO applied to the Company for additional explanations. As of the date of this report, the Office has not commented on the explanations submitted by the Company. In the case of one complaint, regarding breach of personal data protection rules, the President of the Personal Data Protection Office issued an admonition regarding breach of the provisions of article 6, item 1 of the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC,
• As regards the 3 proceedings initiated in the years 2018-2019, the Company received a decision from the President of the Personal Data Protection Office (one case was dismissed, while in two other cases the President refused to accept the requests from the complaining parties),
• As regards a case from 2018, the Personal Data Protection Office asked the Company to provide additional explanations. As of the date of the present report, the Office has not commented on the explanations submitted by the Company,
• In August 2020 the Personal Data Protection Office initiated administrative proceedings regarding breach of personal data protection regulations (the breach concerned protection of personal data in connection with the loss of documents by a courier company as well as releasing the documents by a courier company’s employees to an unauthorized third party). The Company provided extensive explanations. The President of the Personal Data Protection Office conducted an investigation as a result of which evidence was gathered which was sufficient to issue a decision in the matter of the logistics process breach. The decision has not been issued yet.

Moreover, Cyfrowy Polsat S.A .received 13 requests from the Personal Data Protection Office regarding reported cases of breach of personal data protection.

Security of products and services

Each new service introduced to the market is analyzed from the point of view of security still at the design stage. Key requirements are defined, and all components are verified before the commercial launch.

Polsat Plus Group is aware that services offered by it have an impact on the daily sense of security of millions of Poles. Apart from the cooperation with water and mountain rescue teams, a good example of this is the service called “Gdzie Jest Bliski” (Where is my relative), or a new generation Parental Control application, which has been developed by parents for parents.

A mobile phone with an active SIM card is all that is required to start locating relatives. There is no need to install any additional software or enter complicated settings to the phone. A person searching for location – e.g. a parent – activates the service and adds a phone number of his/her relative whom they wish to protect. The person being located must express consent to having their mobile phone located. Such consent means that it will be only the parent who will be able to determine the location, so as to make sure that no unauthorized person can obtain information about the location of a relative or child.

Identity theft, or take-over of user accounts, is one of the threats encountered in the Internet. Identity in the Internet also means passwords, logins, PIN numbers as well as all other information that can be linked to a specific person. Such data is leaked or stolen, and then placed on various platforms of the Internet where the data can be bought by cybercriminals and used for extortions or account hacking. Though you cannot erase the things that went into the Internet, it is worth checking what the Internet knows about us.

Fight against piracy

In Poland the level of piracy is much higher than on the developed markets of Western Europe or elsewhere in the world, and the costs of this phenomenon affect not only the authors, but also the State Treasury and the labor market. The services of illegal access to content are usually very well organized and provided in order to obtain financial gains. The sector of such services has grown to the size exceeding the size of legal services offering online video content in Poland. According to Deloitte’s estimates, Polish economy loses over PLN 3bn per year because of piracy. It is the sum which could cover approx. 30% of annual expenditures of the State Treasury on culture and media or make it possible to purchase four cinema tickets for every citizen.

The educational project, called ”Piractwo.tv,” (Piracy.tv) was ultimately completed in 2020 as the last training session was conducted for the policemen and prosecutors involved in combatting theft of intellectual property in the Internet. Thus, thanks to “Piractwo.tv” project, realized in cooperation with the Main Police Headquarters, the trainers from Sygnał Association reached all the police units in Poland  which deal with this this type of crime. Due to the pandemics, work has started on developing the web version of the training program and creation of an educational platform for the needs of the policemen and police academies. Sessions for individual police units, interested in training were also held during the early months of 2020.

In 2020 Sygnał Association continued  activities aimed at reducing the availability of illegal sources of TV content in the Internet and of reducing the revenues that pirate services obtain from illegal content distribution.. During previous years a campaign called “follow the money” was launched. The campaign involved monitoring of the services which violate the broadcasters’ rights, with a table containing aggregated data on cases of rights violation having been created, as well as permanent cooperation having been initiated with the payment processing companies whose services criminals used to derive financial benefits from their illegal activities. In 2020 the development of this area of the Association’s activity continued, thanks to which it was possible not only to reduce the presence of ads from major advertisers in pirate web services and prevent payments for access to illegal content via trusted providers of financial services and telecommunication operators but also to reduce substantially the scale of the illegal activities involving sale, via Internet auctions, of activation codes enabling access to illegal content. In 2020, thanks to the daily, systematic work covering this area the number of such illegal auctions was reduced fourfold compared to 2019.

Elections of the organization’s authorities took place in June 2020. Teresa Wierzbowska, Advisor to the Management Board of Cyfrowy Polsat for public affairs, has been reelected the President of “Sygnał” Association. Also Łukasz Sternowski, Manager of the Intellectual Property Protection Unit in Cyfrowy Polsat, is a Member of the Management Board of the Association.