GDPR
Data protection on the platform
For entities' data protection officers and legal teams: who does what under the GDPR, where the data is kept, who else handles it and what the platform guarantees.
In short
- The entity is the controller. Olhar Panorâmico - Unipessoal, Lda. is a processor and handles data only on documented instructions.
- Server, database, files and backups hosted in the European Union.
- Services that process data outside the European Economic Area are listed one by one, with the applicable safeguard.
- Entity data is not used to train AI models.
- Full data export and deletion at the end of the contract.
1. Who is responsible for what
The entity using the platform, whether a council, an assembly or a parish board, is the controller: it decides the purposes, the retention periods and who has access, and answers data subjects through its data protection officer.
Olhar Panorâmico - Unipessoal, Lda., which develops and operates the Plenários platform under the Loading brand, is a processor (GDPR, Art. 28). It processes data only to deliver the contracted service and on the entity's documented instructions, under a data processing agreement covering the matters in Article 28(3): confidentiality, security, further processors, assistance with data subject requests and impact assessments, return and deletion at the end of the contract, and information for audits.
Regulation (EU) 2016/679 (GDPR) and Portuguese Law 58/2019 of 8 August, which implements it in Portugal, apply. The data Olhar Panorâmico - Unipessoal, Lda. processes on its own account, such as demo requests made on this site, is covered in the Privacy policy.
2. What data goes through the platform
- Members of the bodies and participants: identification, position, contact details, attendance, roll-call votes, contributions and statements of vote.
- Entity users: account, profile, permissions, access logs and, where provided, the mobile number for two-step verification.
- Sessions: audio and video recordings, transcripts, documents, proposed minutes and approved minutes.
- Public: the data of people who sign up to speak or submit a request on a portal.
- Voiceprints of elected members who consent, only when the entity enables speaker identification by voice. This is biometric data (GDPR, Art. 9) and is processed on the basis of each member's explicit consent, which can be withdrawn at any time.
In secret ballots, the way each person voted is never linked to them: the platform knows the result, the count and who took part, and stores nothing more.
3. Where the data is kept
The platform server, the database and the mail server are hosted within the territory of the European Union. Files, such as documents, published minutes and recordings sent for transcription, and backups are kept in storage under European Union jurisdiction, with a backup vault whose retention is enforced by the provider and not only by the platform.
In front of the server sits a global delivery network that filters unwanted traffic and terminates the encrypted connection. The specialised transcription and drafting services are listed, each with its location, in the register below.
4. Sub-processor register
Technology providers the platform may use to deliver the service, with their role, the data involved, where it is processed and the mechanism that applies when data leaves the European Economic Area. It is the same register each portal publishes at /transparencia-ia/subcontratantes. Changes are notified to entities under the data processing agreement.
| Provider and location | Role | Data involved | Transfer mechanism |
|---|---|---|---|
| GladiaFrance (EU) | Automatic transcription of session audio | Session audio recordings and technical metadata | Processing within the EEA, no transfer to a third country |
| SpeechmaticsUnited Kingdom | Automatic transcription of session audio (alternative service) | Session audio recordings and technical metadata | EU adequacy decision for the United Kingdom |
| pyannoteAIFrance (EU) | Speaker separation and voice identification, only when enabled by the entity and with the elected member's consent | Audio excerpts and voiceprints of those who consented | Processing within the EEA, no transfer to a third country |
| AnthropicUnited States | Language models for proposed minutes and assisted drafting | Transcripts, documents and session details | EU standard contractual clauses and/or the EU-US Data Privacy Framework, depending on the service |
| OpenAIUnited States | AI models for document analysis, text extraction from documents and drafting | Texts, documents and document images | EU standard contractual clauses and/or the EU-US Data Privacy Framework, depending on the service |
| CloudflareGlobal network, with EU presence | Content delivery, traffic protection and file storage | Platform files and technical access logs | EU standard contractual clauses and/or the EU-US Data Privacy Framework, depending on the service |
| PTispEuropean Union | Hosting of the platform server, database and mail server | All data processed on the platform, including the emails sent | Processing within the EEA, no transfer to a third country |
| SMSOnline.ptPortugal (EU) | Two-step verification SMS and service alerts | Mobile numbers and message text | Processing within the EEA, no transfer to a third country |
| OpenStreetMap Foundation (Nominatim)United Kingdom | Converting addresses into coordinates for portal maps | Addresses of public venues, never personal data | EU adequacy decision for the United Kingdom |
| European Central BankGermany (EU) | USD/EUR reference rate for platform usage costs | No personal data | Processing within the EEA, no transfer to a third country |
Register last reviewed: 24 September 2026.
5. International transfers
When a service processes data outside the European Economic Area, Chapter V of the GDPR applies: a European Commission adequacy decision, such as the one for the United Kingdom or the EU-US Data Privacy Framework for certified companies, or standard contractual clauses, with supplementary measures where needed. Data is sent only to produce the requested result, such as a transcript or proposed minutes, on contractual terms designed to prevent those services from using it for other purposes.
6. Artificial intelligence and model training
Entity data is not used to train artificial intelligence models. Olhar Panorâmico - Unipessoal, Lda. does not use it to train its own models, and AI providers are engaged on terms that prevent them from using it for general training, to the extent each service allows and guarantees. The role of AI, its limits and human oversight are described in Transparency in the use of AI.
7. Security of processing
Technical and organisational measures appropriate to the risk (GDPR, Art. 32), including:
- Sign-in always requires a verification code, by email and also by SMS when a mobile number is registered; sessions have an inactivity limit and a maximum length.
- Each organisation sees only its own data, and permissions by role and by body are enforced on data access, not just on screen.
- Credentials for external services and voting device keys are encrypted before they reach the database.
- An audit log with author and date, where each entry is sealed from the previous one, so any change midway shows.
- Nightly backups, confirmed at the destination, and a vault with enforced retention against alteration and deletion.
- Closing a session in which decisions were taken seals the votes and the attendance that counts towards the quorum.
8. Personal data breaches
In the event of a personal data breach, the entity is informed without undue delay, with the information it needs to meet its obligations to notify the Portuguese authority (CNPD) within 72 hours and, where applicable, the data subjects (GDPR, Arts. 33 and 34). Anyone who finds a security flaw can report it to [email protected].
9. Data subject rights
Data subject rights are exercised with the controlling entity, through the contact details on its portal or its data protection officer. Olhar Panorâmico - Unipessoal, Lda. provides the assistance set out in the contract, for instance to locate, export, correct or delete data. If a request reaches us directly, we forward it to the entity without delay.
10. Retention, export and end of contract
Retention periods are decided by the entity, not by the supplier. The entity can ask for a full export of its data, in JSON and CSV, with documents, recordings and minutes in their original formats, at no exit cost. At the end of the contract, the data is returned to the entity and then deleted, including from backups at the end of their retention cycle, unless the law requires it to be kept.
11. Documentation for procurement
For procurement, we provide the data processing agreement, the sub-processor register, the description of security measures and support for any data protection impact assessment (GDPR, Art. 35) the entity decides to carry out. Clients can also consult the trust centre inside the platform, with live security measurements. Requests to [email protected].