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The General Data Protection Regulation (GDPR) has already raised many controversies, and one of the biggest ones is certainly which documents are required. For example, often you see companies who think having a privacy policy and a consent form on their website is enough; however, this is only a small part of the documents that are required to be fully compliant with this new privacy regulation.
Therefore, we created a list of GDPR documentation requirements to help you find all mandatory documents at one place . Please note that the names of the documents are not prescribed by the GDPR, so you may use some other titles; you also have a possibility to merge some of these documents.
Mandatory documents and records required by EU GDPR
Here are the documents that you must have if you want to be fully GDPR compliant:
Privacy Notice (Articles 12, 13, and 14) – this document (which can also be published on your website) explains in simple words how you will process personal data of your customers, website visitors, and others.
Employee Privacy Notice (Articles 12, 13 and 14) – explains how your company is going to process personal data of your employees (which could include health records, criminal records, etc.).
Data Retention Policy (Articles 5, 13, 17, and 30) – describes the process of deciding how long a particular type of personal data will be kept, and how it will be securely destroyed.
Data Retention Schedule (Article 30) – lists all of your personal data and describes how long each type of data will be kept.
Parental Consent Form (Article 8) – if the data subject is below the age of 16 years, then a parent needs to provide the consent for processing personal data.
Supplier Data Processing Agreement (Articles 28, 32, and 82) – you need this document to regulate data protection with a processor or any other supplier.
Data Breach Register (Article 33) – this is where you’ll record all of your data breaches. (Hopefully, it will be very short.)
Data Breach Notification Form to the Supervisory Authority (Article 33) – in case you do have a data breach, you’ll need to notify the Supervisory Authority in a formal way.
Data Breach Notification Form to Data Subjects (Article 34) – again, in case of a data breach, you’ll have the unpleasant duty to notify data subjects in a formal way.
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French data protection authority says Google Analytics is in violation of GDPR
The French national data protection authority, CNIL, issued a formal notice to managers of an unnamed local website today arguing that its use of Google Analytics is in violation of the European Union’s General Data Protection Regulation, following a similar decision by Austria last month.
The root of the issue stems from the website’s use of Google Analytics, which functions as a tool for managers to track content performance and page visits. CNIL said the tool’s use and transfer of personal data to the U.S. fails to abide by landmark European regulations because the U.S. was deemed to not have equivalent privacy protections.
European regulators including CNIL have been investigating such complaints over the last two years, following a decision by the EU’s top court that invalidated the U.S.’s “Privacy Shield” agreement on data transfers. NOYB, the European Center for Digital Rights, reported 101 complaints in 27 member states of the EU and 3 states in the European Economic Area against data controllers who conduct the transatlantic transfers.
Privacy Shield, which went into effect in August of 2016, was a “self-certification mechanism for companies established in the United States of America,” according to CNIL.
Originally, the Privacy Shield was considered by the European Commission to be a sufficient safeguard for transferring personal data from European entities to the United States. However, in 2020 the adequacy decision was reversed due to no longer meeting standards.
An equivalency test was used to compare European and U.S. regulations which immediately established the U.S.’s failure to protect the data of non-U.S. citizens. European citizens would remain unaware that their data is being used and how it is being used, and they cannot be compensated for any misuse of data, CNIL found.
CNIL concluded that Google Analytics does not provide adequate supervision or regulation, and the risks for French users of the tool are too great.
“Indeed, if Google has adopted additional measures to regulate data transfers within the framework of the Google Analytics functionality, these are not sufficient to exclude the possibility of access by American intelligence services to this data,” CNIL said.
The unnamed site manager has been given a month to update its operations to be in compliance with GDPR. If the tool cannot meet regulations, CNIL suggests transitioning away from the current state of Google Analytics and replacing it with a different tool that does not transmit the data.
The privacy watchdog does not call for a ban of Google Analytics, but rather suggests revisions that follow the guidelines. “Concerning the audience measurement and analysis services of a website, the CNIL recommends that these tools be used only to produce anonymous statistical data, thus allowing an exemption from consent if the data controller ensures that there are no illegal transfers,” the watchdog said.
Most management systems, compliance, and certification projects require documented policies, procedures, and work instructions. GDPR compliance is no exception. Documentation of policies and processes are vital to achieve compliance.
ITG GDPR Documentation Toolkit gives you a complete set of easily customizable GDPR-compliant documentation templates to help you demonstrate your compliance with the GDPR’s requirements quickly, easily, and affordably.
“Having recently kicked off a GDPR project with a large international organisation I was tasked with creating their Privacy Compliance Framework. The GDPR toolkit provided by IT Governance proved to be invaluable providing the project with a well organised framework of template documents covering all elements of the PIMS framework. It covers areas such as Subject Access Request Procedure, Retention of Records Procedure and Data Protection Impact Assessment Procedure helping you to put in practice policies and procedures to enable the effective management of personal information on individuals. For anyone seeking some support with their GDPR plans the toolkit is well work consideration.”
Two-thirds of remote workers risk potentially breaching GDPR guidelines by printing out work-related documents at home, according to a new study from Go Shred.
The confidential shredding and records management company discovered that 66% of home workers have printed work-related documents since they began working from home, averaging five documents every week. Such documents include meeting notes/agendas (42%), internal documents including procedure manuals (32%), contracts and commercial documents (30%) and receipts/expense forms (27%).
Furthermore, 20% of home workers admitted to printing confidential employee information including payroll, addresses and medical information, with 13% having printed CVs or application forms.
The issue is that, to comply with the GDPR, all companies that store or process personal information about EU citizens within EU states are required to have an effective, documented, auditable process in place for the collection, storage and destruction of personal information.
However, when asked whether they have disposed of any printed documents since working from home, 24% of respondents said they haven’t disposed of them yet as they plan to take them back to the office and a further 24% said they used a home shredding machine but disposed of the documents in their own waste. This method of disposal is not recommended due to personal waste bins not providing enough security for confidential waste and therefore still leaving employers open to a data breach and potential fines, Go Shred pointed out.
Most concerning of all, 8% of those polled said they have no plans to dispose of the work-related documents they have printed at home, with 7% saying they haven’t done so because they do not know how to.
Personal data breach notification procedures under the GDPR
Organizations must create a procedure that applies in the event of a personal data breach under Article 33 – “Notification of a personal data breach to the supervisory authority” – and Article 34 of the GDPR – “Communication of a personal data breach to the data subject”.
Help with creating a data breach notification template
The picture above is an example of what a data breach notification might look like – available from the market-leading EU GDPR Documentation Toolkit – which sets out the scope of the procedure, responsibilities and the steps that will be taken by the organization to communicate the breach from:
A privacy notice is a public statement of how your organisation applies data protection principles to processing data. It should be a clear and concise document that is accessible by individuals.
Articles 12, 13 and 14 of the GDPR outline the requirements on giving privacy information to data subjects. These are more detailed and specific than in the UK Data Protection Act 1998 (DPA).
The GDPR says that the information you provide must be:
Concise, transparent, intelligible and easily accessible;
Written in clear and plain language, particularly if addressed to a child; and
Free of charge.
Help with creating a privacy notice template
The privacy notice should address the following to sufficiently inform the data subject:
If you are looking for a complete set of GDPR templates to help with your compliance project, you may be interested in the market-leading EU GDPR Documentation Toolkit. This toolkit is designed and developed by expert GDPR practitioners, and has been used by thousands of organisations worldwide. It includes:
A complete set of easy-to-use and customisable documentation templates, which will save you time and money and ensure GDPR compliance;
Helpful dashboards and project tools to ensure complete GDPR coverage;
With the advent of the European Union (EU) deadline for General Data Protection Regulation (GDPR) (EU 2016/679 regulation) coming up on 25 May 2018, many organizations are addressing their data gathering, protection and retention needs concerning the privacy of their data for EU citizens and residents. This regulation has many parts, as ISACA has described in many of its recent publications and events, but all of the efforts revolve around the protection and retention of the EU participants’ personal information. The 6 main areas for data protection defined in this regulation are:
Data security controls need to be, by default, active at all times. Allowing security controls to be optional is not recommended or even suggested. “Always on” is the mantra for protection.
These controls and the protection they provide must be embedded inside all applications. The GDPR view is that privacy is an essential part of functionality, the security of the system and its processing activities.
Along with embedding the data protection controls in applications, the system must maintain data privacy across the entire processing effort for the affected data. This end-to-end need for protection includes collection efforts, retention requirements and even the new “right to be forgotten” requirement, wherein the customer has the right to request removal of their data from an organization’s storage.
Complete data protection and privacy adds full-functional security and business requirements to any processing system in this framework for data privacy. It provides that business requirements and data protection requirements be equally important during the business process.
The primary requirement for protection within the GDPR framework demands the security and privacy controls implemented are proactive rather than reactive. As its principal goal, the system needs to prevent issues, releases and successful attacks. The system is to keep privacy events from occurring in the first place.
With all of these areas needed under GDPR, the most important point for organizations to understand about GDPR is transparency. The EU wants full disclosure of an organization’s efforts, documentation, reviews, assessments and results available for independent third-party review at any point. The goal is to ensure privacy managed by these companies is not dependent upon technology or business practices. It needs to be provable to outside parties and, therefore, acceptable. The EU has purposely placed some strong fine structures and responses into this regulation to ensure compliance.
Having reviewed various organizational efforts in preparation for GDPR implementation, it has been found that it is good practice to look at these 6 areas for all the collected and retained data, not just EU-based data. This zero-tolerance approach to data breaches is purposely designed to be stringent and strong. Good luck to all in meeting and maintaining the data privacy and security requirements of GDPR.
Those who have studied the Regulation will be aware that there are many references to certification schemes, seals and marks. The GDPR encourages the use of certification schemes like ISO 27001 to serve the purpose of demonstrating that the organisation is actively managing its data security in line with international best practice.
Managing people, processes and technology
ISO 27001 is the international best practice standard for information security, and is a certifiable standard that is broad-based and encompasses the three essential aspects of a comprehensive information security regime: people, processes and technology. By implementing measures to protect information using this three-pronged approach, the company is able to defend itself from not only technology-based risks, but other, more common threats, such as poorly informed staff or ineffective procedures.
By implementing ISO 27001, your organisation will be deploying an ISMS (information security management system): a system that is supported by top leadership, incorporated into your organisation’s culture and strategy, and which is constantly monitored, updated and reviewed. Using a process of continual improvement, your organisation will be able to ensure that the ISMS adapts to changes – both in the environment and inside the organisation – to continually identify and reduce risks.
What does the GDPR say?
The GDPR states clearly in Article 32 that “the controller and the processor shall implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk, including inter alia as appropriate:
the pseudonymisation and encryption of personal data;
the ability to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services;
the ability to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident;
a process for regularly testing, assessing and evaluating the effectiveness of technical and organisational measures for ensuring the security of the processing.”
Let’s look at these items separately:
Encryption of data is recommended by ISO 27001 as one of the measures that can and should be taken to reduce the identified risks. ISO 27001:2013 outlines 114 controls that can be used to reduce information security risks. Since the controls an organisation implements are based on the outcomes of an ISO 27001-compliant risk assessment, the organisation will be able to identify which assets are at risk and require encryption to adequately protect them.
One of ISO 27001’s core tenets is the importance of ensuring the ongoing confidentiality, integrity and availability of information. Not only is confidentiality important, but the integrity and availability of such data is critical as well. If the data is available but in a format that is not usable because of a system disruption, then the integrity of that data has been compromised; if the data is protected but inaccessible to those who need to use it as part of their jobs, then the availability of that data has been compromised.
Risk assessment
ISO 27001 mandates that organisations conduct a thorough risk assessment by identifying threats and vulnerabilities that can affect an organisation’s information assets, and to take steps to assure the confidentiality, availability and integrity (CIA) of that data. The GDPR specifically requires a risk assessment to ensure an organisation has identified risks that can impact personal data.
Business continuity
ISO 27001 addresses the importance of business continuity management, whereby it provides a set of controls that will assist the organisation to protect the availability of information in case of an incident and protect critical business processes from the effects of major disasters to ensure their timely resumption.
Testing and assessments
Lastly, organisations that opt for certification to ISO 27001 will have their ISMSs independently assessed and audited by an accredited certification body to ensure that the management system meets the requirements of the Standard. Companies need to regularly review their ISMS and conduct the necessary assessments as prescribed by the Standard in order to ensure it continues protecting the company’s information. Achieving accredited certification to ISO 27001 delivers an independent, expert assessment of whether you have implemented adequate measures to protect your data.
The requirements to achieve compliance with ISO 27001 of course do not stop there. Being a broad standard, it covers many other elements, including the importance of staff awareness training and leadership support. ISO 27001 has already been adopted by thousands of organisations globally, and, given the current rate and severity of data breaches, it is also one of the fastest growing management system standards today.
The GDPR will replace these with a pan-European regulatory framework effective from 25 May 2018. The GDPR applies to all EU organizations – whether commercial business or public authority – that collect, store or process the personal data (PII) of EU individuals.
Organizations based outside the EU that monitor or offer goods and services to individuals in the EU will have to observe the new European rules and adhere to the same level of protection of personal data. This potentially includes organizations everywhere in the world, regardless of how difficult it may be to enforce the Regulation. Compliance consultant must know the following 9 tenants of the GDPR.
Supervisory Authority – A one-stop shop provision means that organizations will only have to deal with a single supervisory authority, not one for each of the EU’s 28 member states, making it simpler and cheaper for companies to do business in the EU.
Breach Disclosure – Organizations must disclose and document the causes of breaches, effects of breaches, and actions taken to address them.
Processor must be able to provide “sufficient guarantees to implement appropriate technical and organizational measures” to ensure that processing will comply with the GDPR and that data subjects’ rights are protected. This requirement flows down the supply chain, so a processor cannot subcontract work to a second processor without the controller’s explicit authorization. If requested by subject you must cease processing and using his or her data for some limited period of time.
Data Consent – The Regulation imposes stricter requirements on obtaining valid consent from individuals to justify the processing of their personal data. Consent must be “freely given, specific, informed and unambiguous indication of the individual’s wishes”. The organization must also keep records so it can demonstrate that consent has been given by the relevant individual. Data can only be used for the purposes that data subject originally explicitly consented. You must obtain and document consent for only one specific purpose at a time.
Right to be forgotten – Individuals have a right to require the data controller to erase all personal data held about them in certain circumstances, such as where the data is no longer necessary for the purposes for which it was collected. If requested by subject, you must erase their data on premises, in apps and on devices.
Data portability – Individuals will have the right to transfer personal data from one data controller to another where processing is based on consent or necessity for the performance of a contract, or where processing is carried out by automated means
Documentation – The Regulation requires quite a bit of documentation. In addition to the explicit and implicit requirements for specific records (especially including proof of consent from data subjects), you should also ensure that you have documented how you comply with the GDPR so that you have some evidence to support your claims if the supervisory authority has any cause to investigate.
Fines – Major noncompliance of the law will be punishable by fines of up to either 4% or €20 million of group annual worldwide turnover.
Data protection by design – Organization must ensure data security and data privacy across cloud and endpoints as well as design their system and processes that protects from unauthorized data access and malware. Specifically, organizations must take appropriate technical and organizational measures before data processing begin to ensure that it meets the requirements of the Regulation. Data privacy risks must be properly assessed, and controllers may use adherence to approved codes of conduct or management system certifications, such as ISO 27001, to demonstrate their compliance.
How to improve information security under the GDPR
Although many businesses understand the importance of implementing the right procedures for detection, report and investigate a data breach, but not many are aware of how to go about this effectively, especially during implementation phase.
Seven steps that can help you prevent a data breach:
Find out where your personal information resides and prioritize your data.
Identify all the risks that could cause a breach of your personal data.
Apply the most appropriate measures (controls) to mitigate those risks.
Implement the necessary policies and procedures to support the controls.
Conduct regular tests and audits to make sure the controls are working as intended.
Review, report and update your plans regularly.
Implement comprehensive and robust ISMS.
ISO 27001, the international information security standard, can help you achieve all of the above and protect all your other confidential company information, too. To achieve GDPR compliance, feel free to contact us for more detail on implementation.
As part of an EU General Data Protection Regulation (GDPR) compliance project, organisations will need to map their data and information flows in order to assess their privacy risks. This is also an essential first step for completing a data protection impact assessment (DPIA), which is mandatory for certain types of processing.
The key elements of data mapping
To effectively map your data, you need to understand the information flow, describe it and identify its key elements.
1. Understand the information flow
An information flow is a transfer of information from one location to another, for example:
From inside to outside the European Union; or
From suppliers and sub-suppliers through to customers.
2. Describe the information flow
Walk through the information lifecycle to identify unforeseen or unintended uses of data. This also helps to minimise what data is collected.
Make sure the people who will be using the information are consulted on the practical implications.
Consider the potential future uses of the information collected, even if it is not immediately necessary.
3. Identify its key elements
Data items
What kind of data is being processed (name, email, address, etc.) and what category does it fall into (health data, criminal records, location data, etc.)?
Formats
In what format do you store data (hardcopy, digital, database, bring your own device, mobile phones, etc.)?
Transfer method
How do you collect data (post, telephone, social media) and how do you share it internally (within your organisation) and externally (with third parties)?
Location
What locations are involved within the data flow (offices, the Cloud, third parties, etc.)?
Accountability
Who is accountable for the personal data? Often this changes as the data moves throughout the organisation.
Access
Who has access to the data in question?
The key challenges of data mapping
Identifying personal data Personal data can reside in a number of locations and be stored in a number of formats, such as paper, electronic and audio. Your first challenge is deciding what information you need to record and in what format.
Identifying appropriate technical and organizational safeguards The second challenge is likely to be identifying the appropriate technology – and the policy and procedures for its use – to protect information while also determining who controls access to it.
Understanding legal and regulatory obligations Your final challenge is determining what your organisation’s legal and regulatory obligations are. As well as the GDPR, this can include other compliance standards, such as the Payment Card Industry Data Security Standard (PCI DSS) and ISO 27001.Once you’ve completed these three challenges, you’ll be in a position to move forward, gaining the trust and confidence of your key stakeholders.
Data flow mapping
To help you gather the above information and consolidate it into one area, Vigilant Software, a subsidiary of IT Governance, has developed a data flow mapping tool with a specific focus on the GDPR.
Accelerate your GDPR compliance implementation project with the market-leading EU GDPR Documentation Toolkit used by hundreds of organizations worldwide, now with significant improvements and new content for summer 2017:
A complete set of easy-to-use and customizable documentation templates, which will save you time and money, and ensure compliance with the GDPR.
Easy-to-use dashboards and project tools to ensure complete coverage of the GDPR.
Direction and guidance from expert GDPR practitioners.
Includes two licenses for the GDPR Staff Awareness E-learning Course.
The General Data Protection Regulation (GDPR) is a new law that will harmonize data protection in the European Union (EU) and will be enforced from May 25, 2018. It aims to protect EU residents from data and privacy breaches, and has been introduced to keep up with the modern digital landscape.
Who needs to comply with the GDPR?
The GDPR will apply to all organizations outside of the EU that process the personal data of EU residents.
Non-compliance can result in hefty fines of up to 4% of annual global turnover or €20 million $23.5 million) – whichever is greater.
Organizations that are compliant with the new Regulation will also find that their processes and contractual relationships are more robust and reliable.
What do US organizations need to do to comply with the GDPR?
The transition period for compliance with the GDPR ends in May 2018. This means that organizations now have less than ten months to make sure they are compliant.
For US organizations, the most significant change concerns the territorial reach of the GDPR.
The GDPR will supersede the current EU Data Protection Directive. Under the current Regulation, organizations without a physical presence or employees in the EU have one main compliance issue to deal with: How to legally transfer data out of the EU. The EU–US Privacy Shield provides such a mechanism for compliance.
Almost all US organizations that collect or process EU residents’ data will need to comply fully with the requirements of the GDPR. US organizations without a physical EU presence must also appoint a GDPR representative based in a Member State.
Save 10% on your essential guide to the GDPR and the EU–US Privacy Shield
August’s book of the month is the ideal resource for anyone wanting a clear primer on the principles of data protection and their new obligations under the GDPR and the EU–US Privacy Shield.
Overview: DISC WinerySecure™ is a tailored cybersecurity and compliance service for small and mid-sized wineries. These businesses are increasingly reliant on digital systems (POS, ecommerce, wine clubs), yet often lack dedicated security staff. Our solution is cost-effective, easy to adopt, and customized to the wine industry.
Wineries may not seem like obvious cyber targets, but they hold valuable data—customer and employee details like social security numbers, payment info, and birthdates—that cybercriminals can exploit for identity theft and sell on the dark web. Even business financials are at risk.
Target Clients:
Wineries with 100–500 employees
Using POS, wine club software, ecommerce, or logistics systems
Limited or no in-house IT/security expertise
Service Bundles
1. Risk & Compliance Assessment(One-Time or Annual)
1. Strategic importance of discretion When two major companies are negotiating a merger or acquisition, even a minor leak can damage stock prices, derail the process, or collapse the deal entirely. A confidential environment is essential to preserve each party’s strategic advantage during secretive stages of the negotiation.
2. Maintaining competitive secrecy By keeping a forthcoming deal under wraps, a company can gain from stealthy operations—honing tactics and announcements without alerting rivals or disrupting the market prematurely.
3. Protecting sensitive materials during due diligence The due diligence stage demands access to proprietary analytics, trade secrets, and financial documents. A properly secured virtual data room (VDR) ensures these materials can be reviewed without risking unwanted exposure.
4. Internal stability amid uncertainty Beyond market reactions, confidentiality helps stabilize employee morale. Rumors of acquisitions can breed anxiety among staff; controlled disclosure helps maintain calm until formal announcements are made .
5. Why virtual is preferred over physical rooms Compared to traditional physical data rooms or email-based exchanges, VDRs offer encrypted, centralized, and remotely accessible document storage. They support multiple users across time zones and locales, making them far more efficient and secure
6. Advanced organization and control tools Modern VDRs include features like hierarchical tagging (as in ShareVault’s platform), robust document indexing, full-text search, and flexible file rights. Admins can finely tune access—for instance, disabling copying, printing, or even screenshots—and apply watermarks with expiration settings .
7. Enhanced transparency, auditability, and efficiency These platforms offer complete audit trails, Q&A sections, real-time alerts, and analytics. Participants can track activity, identify engagement patterns, and streamline due diligence, speeding up deal completion and improving oversight
Virtual Data Rooms (VDRs) are essential tools in mergers and acquisitions, providing a secure platform for sharing confidential documents during due diligence. They enable controlled access to sensitive information, supporting informed decision-making and effective risk management. In today’s digital landscape, where information is a critical asset, VDRs enhance corporate governance by promoting transparency, accountability, and compliance. As businesses face increasing regulatory and operational demands, adopting VDRs is not just a smart choice but a strategic necessity for maintaining strong governance and operational integrity.
Virtual data rooms are indispensable in confidential M&A contexts. They effectively combine security, efficiency, and collaboration in ways that physical or email-based systems simply cannot. The advanced features—granular permissions, audit logs, analytics, and query tools—are not just conveniences; they’re game-changers that help drive deals forward more smoothly and securely.
To truly elevate the experience, VDR providers Sharevault prioritize user-friendly interfaces—think intuitive document sorting, drag & drop, clear timestamps—and strike a better balance between robust security measures and seamless usability. When technical strength aligns with an intuitive user experience, virtual data rooms fulfill their potential, making complex, high-stakes M&A processes feel nearly effortless.
Information Security & Privacy aspect of the M&A process, especially focusing on how confidentiality, integrity, and controlled access are preserved throughout.
1. Confidentiality of Deal Intentions and Parties Involved
In early M&A stages, even the existence of negotiations must be tightly guarded. Leakage of deal discussions can lead to:
Stock volatility
Competitor disruption
Supplier or customer anxiety
Employee attrition
To prevent this, non-disclosure agreements (NDAs) are signed before sharing even basic information. VDRs enforce this by granting access only to vetted parties and logging all user activity, discouraging leaks.
2. Due Diligence Security
This is the most data-sensitive phase. Buyers review:
Financial statements
Tax filings
Contracts
Intellectual property details
Litigation history
Cyber risk posture
Each document represents potential liability if exposed. A secure VDR ensures:
End-to-end encryption (AES-256 or higher)
Multi-factor authentication (MFA)
Granular access control down to the file or section level
View-only access with no downloads, printing, or screen capture
Watermarks with user IPs and timestamps
3. Auditability and Legal Traceability
To defend the integrity of the deal and respond to any post-deal disputes, every interaction must be tracked:
Who viewed what, when, and for how long
Questions asked and answered (Q&A logs)
Document version histories
These logs are part of legal documentation and are often retained long after the deal closes.
4. Cybersecurity Risk Assessment as a Deal Factor
Buyers often assess the seller’s cybersecurity posture as part of due diligence. Poor security (e.g., history of breaches, lax controls, outdated tech) may reduce valuation or kill the deal. Common items reviewed include:
Security policies
Incident response history
SOC 2 / ISO 27001 certifications
Penetration test results
Data breach disclosures
In this case, the VDR may host security documentation that itself must be securely handled.
5. Insider Risk and Privilege Escalation Control
Not all threats are external. Internal actors—disgruntled employees, opportunists, or even curious insiders—can leak or misuse information. VDRs address this by:
Role-based access (e.g., legal, finance, HR teams see only what’s necessary)
IP restriction (limit access by location)
Time-bound access with auto-expiry
Real-time alerts on suspicious behavior (e.g., large downloads)
6. Data Sovereignty and Compliance Risks
Cross-border M&A may involve GDPR, HIPAA, CCPA, or local data protection laws. VDRs must:
Store data in approved jurisdictions
Enable redaction tools
Offer data retention and deletion policies in compliance with local law
Failing to do this may introduce legal exposure before the deal even closes.
7. Post-Deal Data Handoff and Secure Closure
After the deal, secure handoff of all data—including audit trails—is essential. VDRs often allow data archiving in encrypted format for legal teams. Proper exit procedures also include:
Revoking third-party access
Exporting logs for compliance
Certifying destruction of temporary working copies
Final Thoughts
Security in M&A isn’t just about locking down data—it’s about enabling trust between parties while protecting the value of the transaction. A single breach could derail a deal or cause post-acquisition litigation. VDRs that offer bank-grade security, forensic logging, regulatory compliance, and intuitive access control are non-negotiable in high-stakes deals. However, companies must complement technology with clear policies and trained personnel to truly secure the process.
Would you like a framework (e.g., ISO 27001-aligned) to assess the security readiness of an M&A deal? info@deurainfosec.com
1. Evolving Role of Cybersecurity Services Traditional cybersecurity engagements—such as vulnerability patching, audits, or one-off assessments—tend to be short-term and reactive, addressing immediate concerns without long-term risk reduction. In contrast, end-to-end cybersecurity programs offer sustained value by embedding security into an organization’s core operations and strategic planning. This shift transforms cybersecurity from a technical task into a vital business enabler.
2. Strategic Provider-Client Relationship Delivering lasting cybersecurity outcomes requires service providers to move beyond technical support and establish strong partnerships with organizational leadership. Providers that engage at the executive level evolve from being IT vendors to trusted advisors. This elevated role allows them to align security with business objectives, providing continuous support rather than piecemeal fixes.
3. Core Components of a Strategic Cybersecurity Program A comprehensive end-to-end program must address several key domains: risk assessment and management, strategic planning, compliance and governance, business continuity, security awareness, incident response, third-party risk management, and executive reporting. Each area works in concert to strengthen the organization’s overall security posture and resilience.
4. Risk Assessment & Management A strategic cybersecurity initiative begins with a thorough risk assessment, providing visibility into vulnerabilities and their business impact. A complete asset inventory is essential, and follow-up includes risk prioritization, mitigation planning, and adapting defenses to evolving threats like ransomware. Ongoing risk management ensures that controls remain effective as business conditions change.
5. Strategic Planning & Roadmaps Once risks are understood, the next step is strategic planning. Providers collaborate with clients to create a cybersecurity roadmap that aligns with business goals and compliance obligations. This roadmap includes near-, mid-, and long-term goals, backed by security policies and metrics that guide decision-making and keep efforts aligned with the company’s direction.
6. Compliance & Governance With rising regulatory scrutiny, organizations must align with standards such as NIST, ISO 27001, HIPAA, SOC 2, PCI-DSS, and GDPR. Security providers help identify which regulations apply, assess current compliance gaps, and implement sustainable practices to meet ongoing obligations. This area remains underserved and represents an opportunity for significant impact.
7. Business Continuity & Disaster Recovery Effective security programs not only prevent breaches but also ensure operational continuity. Business Continuity Planning (BCP) and Disaster Recovery (DR) encompass infrastructure backups, alternate operations, and crisis communication strategies. Providers play a key role in building and testing these capabilities, reinforcing their value as strategic advisors.
8. Human-Centric Security & Response Preparedness People remain a major risk vector, so training and awareness are critical. Providers offer education programs, phishing simulations, and workshops to cultivate a security-aware culture. Incident response readiness is also essential—providers develop playbooks, assign roles, and simulate breaches to ensure rapid and coordinated responses to real threats.
9. Executive-Level Communication & Reporting A hallmark of high-value cybersecurity services is the ability to translate technical risks into business language. Clear executive reporting connects cybersecurity activities to business outcomes, supporting board-level decision-making and budget justification. This capability is key for client retention and helps providers secure long-term engagements.
Feedback
This clearly outlines how cybersecurity must evolve from reactive technical support into a strategic business function. The focus on continuous oversight, executive engagement, and alignment with organizational priorities is especially relevant in today’s complex threat landscape. The structure is logical and well-grounded in vCISO best practices. However, it could benefit from sharper differentiation between foundational services (like asset inventories) and advanced advisory (like executive communication). Emphasizing measurable outcomes—such as reduced incidents, improved audit results, or enhanced resilience—would also strengthen the business case. Overall, it’s a strong framework for any provider building or refining an end-to-end security program.
In the rapidly evolving landscape of artificial intelligence (AI), Chief Information Security Officers (CISOs) are grappling with the challenges of governance and data provenance. As AI tools become increasingly integrated into various business functions, often without centralized oversight, the traditional methods of data governance are proving inadequate. The core concern lies in the assumption that popular or “enterprise-ready” AI models are inherently secure and compliant, leading to a dangerous oversight of data provenance—the ability to trace the origin, transformation, and handling of data.
Data provenance is crucial in AI governance, especially with large language models (LLMs) that process and generate data in ways that are often opaque. Unlike traditional systems where data lineage can be reconstructed, LLMs can introduce complexities where prompts aren’t logged, outputs are copied across systems, and models may retain information without clear consent. This lack of transparency poses significant risks in regulated domains like legal, finance, or privacy, where accountability and traceability are paramount.
The decentralized adoption of AI tools across enterprises exacerbates these challenges. Various departments may independently implement AI solutions, leading to a sprawl of tools powered by different LLMs, each with its own data handling policies and compliance considerations. This fragmentation means that security organizations often lose visibility and control over how sensitive information is processed, increasing the risk of data breaches and compliance violations.
Contrary to the belief that regulations are lagging behind AI advancements, many existing data protection laws like GDPR, CPRA, and others already encompass principles applicable to AI usage. The issue lies in the systems’ inability to respond to these regulations effectively. LLMs blur the lines between data processors and controllers, making it challenging to determine liability and ownership of AI-generated outputs. In audit scenarios, organizations must be able to demonstrate the actions and decisions made by AI tools, a capability many currently lack.
To address these challenges, modern AI governance must prioritize infrastructure over policy. This includes implementing continuous, automated data mapping to track data flows across various interfaces and systems. Records of Processing Activities (RoPA) should be updated to include model logic, AI tool behavior, and jurisdictional exposure. Additionally, organizations need to establish clear guidelines for AI usage, ensuring that data handling practices are transparent, compliant, and secure.
Moreover, fostering a culture of accountability and awareness around AI usage is essential. This involves training employees on the implications of using AI tools, encouraging responsible behavior, and establishing protocols for monitoring and auditing AI interactions. By doing so, organizations can mitigate risks associated with AI adoption and ensure that data governance keeps pace with technological advancements.
CISOs play a pivotal role in steering their organizations toward robust AI governance. They must advocate for infrastructure that supports data provenance, collaborate with various departments to ensure cohesive AI strategies, and stay informed about evolving regulations. By taking a proactive approach, CISOs can help their organizations harness the benefits of AI while safeguarding against potential pitfalls.
In conclusion, as AI continues to permeate various aspects of business operations, the importance of data provenance in AI governance cannot be overstated. Organizations must move beyond assumptions of safety and implement comprehensive strategies that prioritize transparency, accountability, and compliance. By doing so, they can navigate the complexities of AI adoption and build a foundation of trust and security in the digital age.
For further details, access the article here on Data provenance
Increased Regulatory Complexity: With GDPR, CCPA, HIPAA, and emerging regulations like DORA (EU), EU AI Act businesses are seeking specialized compliance partners.
SME Cybersecurity Prioritization: Mid-sized businesses are investing in vCISO services to bridge expertise gaps without hiring full-time CISOs.
Rise of Cyber Insurance: Insurers are demanding evidence of strong compliance postures, increasing demand for third-party audits and vCISO engagements.
Growth Projections
vCISO market is expected to grow at 17–20% CAGR through 2028.
Compliance automation tools, Process orchestration (AI) and advisory services are growing due to demand for cost-effective solutions.
2. Competitor Landscape
Direct Competitors
Virtual CISO Services by Cynomi, Fractional CISO, and SideChannel
Offer standardized packages, onboarding frameworks, and clear SLA-based services.
Differentiate through cost, specialization (e.g., healthcare, fintech), and automation integration.
Indirect Competitors
MSSPs and GRC Platforms like Arctic Wolf, Drata, Vanta
Provide automated compliance dashboards, sometimes bundled with consulting.
Threat: Position as “compliance-as-a-service,” reducing perceived need for vCISO.
3. Differentiation Levers
What Works in the Market
Vertical Specialization: Deep focus on industries like legal, SaaS, fintech, or healthcare adds credibility.
Thought Leadership: Regular LinkedIn posts, webinars, and compliance guides elevate visibility and trust.
Compliance-as-a-Path-to-Growth: Reframing compliance as a revenue enabler (e.g., “SOC 2 = more enterprise clients”) resonates well.
Emerging Niches
vDPO (Virtual Data Protection Officer) in the EU market.
Posture Maturity Consulting for startups seeking Series A or B funding.
Third-Party Risk Management-as-a-Service as vendor scrutiny rises.
4. SWOT Analysis
Strengths
Weaknesses
Deep expertise in InfoSec & compliance
May lack scalability without automation
Custom vCISO engagements
High-touch model limits price elasticity
Opportunities
Threats
Demand surge in SMBs & startups
Commoditization by automated GRC tools
Cross-border compliance needs (e.g., UK GDPR + US laws)