Jul 15 2023

List of mandatory documents required by EU GDPR

Category: Information Securitydisc7 @ 2:28 pm

Article by Dejan Kosutic

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:

  • Personal Data Protection Policy (Article 24) – this is a top-level document for managing privacy in your company, which defines what you want to achieve and how. See also: Contents of the Data Protection Policy according to GDPR.
  • Privacy Notice (Articles 1213, 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 1213 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 51317, 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.
  • Data Subject Consent Form (Articles 67, and 9) – this is the most common way to obtain consent from a data subject to process his/her personal data. Learn more here: Is consent needed? Six legal bases to process data according to GDPR.
  • 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.
  • DPIA Register (Article 35) – this is where you’ll record all the results from your Data Protection Impact Assessment. See this webinar: Seven steps of Data Protection Impact Assessment (DPIA) according to EU GDPR.
  • Supplier Data Processing Agreement (Articles 2832, and 82) – you need this document to regulate data protection with a processor or any other supplier.
  • Data Breach Response and Notification Procedure (Articles 433, and 34) – it describes what to do before, during, and after a data breach. See also: 5 steps to handle a data breach according to GDPR.
  • 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.


Sep 22 2022

Second Course Exam for Free – ISO 9001, ISO 14001, ISO 27001 & EU GDPR

Category: Information Security,ISO 27kDISC @ 8:30 am

I just wanted to inform you that, at the end of September, Advisera launched “Second Course Exam for Free” promotional campaign. The campaign will start on September 22, and end on September 29, 2022.

Take the ISO 9001 course exam and get the ISO 14001, ISO 13485, or 45001 course exam for free


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Tags: EU GDPR, ISO 13485, ISO 14001, iso 27001, ISO 45001, iso 9001


Feb 10 2022

French data protection authority says Google Analytics is in violation of GDPR

Category: data security,GDPRDISC @ 10:28 pm
French data protection authority says Google Analytics is in violation of GDPR

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. 

source: https://

/french-data-protection-authority-says-google-analytics-is-in-violation-of-gdpr/

GDPR Practitioner Guide

Tags: French data protection authority, gdpr, GDPR Practitioner Guide, Google Analytics


May 24 2021

GDPR compliance without the complexity

Category: GDPRDISC @ 12:53 pm
GDPR Toolkit

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.”

– Chris Prantl

Tags: #GDPR #DataBreachNotification, gdpr compliance, GDPR implementation, GDPR toolkit


Feb 19 2021

66% of Workers Risk Breaching GDPR by Printing Work-Related Docs at Home

Category: GDPRDISC @ 10:27 pm

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.

Source: 66% of Workers Risk Breaching GDPR by Printing Work-Related Docs at Home via Infosecurity Magazine

Tags: GDPR by Printing


Aug 22 2019

‘2019 is the year of enforcement’: GDPR fines have begun

Category: GDPRDISC @ 2:57 pm

The Information Commissioner’s Office levied fines against British Airways and Marriott International for violating the GDPR.

Source: ‘2019 is the year of enforcement’: GDPR fines have begun – Digiday

British Airways faces $230 million fine over GDPR breach
httpv://www.youtube.com/watch?v=CUVrcuIvBOY

Marriott Faces GDPR Fines: A DPO and CISO Discussion
httpv://www.youtube.com/watch?v=5KKXLSnW9Zc

Steps to GDPR Compliance




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Jul 29 2019

5 ways to avoid a GDPR fine

Category: GDPRDISC @ 10:04 am

After the ICO issues $450 million of GDPR fines in a week, be sure you’re not next.
Source: 5 ways to avoid a GDPR fine

GDPR For Consultants – Training Webinar

 

What You Need to Know about General Data Protection Regulation

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Tags: #GDPR #DataBreachNotification, gdpr compliance, GDPR Privacy


Jul 26 2019

How to write a GDPR data breach notification procedure – with template example

Category: Data Breach,GDPR,Information PrivacyDISC @ 2:05 pm

Discover how to write a GDPR data breach notification procedure to help you with your GDPR compliance. Including a free template example. Read now

Source: How to write a GDPR data breach notification procedure – with template example – IT Governance Blog

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:

  • Data processor to data controller;
  • Data controller to supervisory authority; and
  • Data controller to data subject.

 

GDPR Implementation Bundle

 


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Tags: #GDPR #DataBreachNotification


Sep 25 2018

Privacy notice under the GDPR

Category: GDPRDISC @ 8:58 pm

 


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:

  • Who is collecting the data?
  • What data is being collected?
  • What is the legal basis for processing the data?
  • Will the data be shared with any third parties?
  • How will the information be used?
  • How long will the data be stored for?
  • What rights does the data subject have?
  • How can the data subject raise a complaint?

Below is an example of a customisable privacy notice template, available from IT Governance here.

GDPR Privacy Notice Template - Example from the EU GDPR Documentation Toolkit

Example of the privacy notice template available to purchase from IT Governance

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;
  • Direction and guidance from expert GDPR practitioners; and
  • Two licences for the GDPR Staff Awareness E-learning Course.





Tags: GDPR Privacy, GDPR Privacy Notice


Feb 21 2018

Six Essential Data Protection and Privacy Requirements Under GDPR

Category: GDPRDISC @ 10:17 am
gdpr
By Leighton Johnson, CISA, CISM, CIFI, CISSP

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:

  1. 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.
  2. 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.
  3. 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.
  4. 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.
  5. 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.
  6. 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.

Steps to EU GDPR compliance

 






Nov 08 2017

How ISO 27001 can help to achieve GDPR compliance

Category: GDPR,ISO 27kDISC @ 2:44 pm

gdpr

By Julia Dutton

Organizations have until 25 May 2018 to comply with the EU General Data Protection Regulation (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:

  1. the pseudonymisation and encryption of personal data;
  2. the ability to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services;
  3. the ability to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident;
  4. 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.

Related articles:

Read more about ISO 27001 and the GDPR >>>>
GDPR Documentation Toolkit and gap assessment tool >>>>
Understanding the GDPR: General Data Protection Regulation >>>>

 






Oct 18 2017

GDPR essentials and how to achieve compliance

Category: data security,GDPRDISC @ 9:51 am

gdpr

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:

  1. Find out where your personal information resides and prioritize your data.
  2. Identify all the risks that could cause a breach of your personal data.
  3. Apply the most appropriate measures (controls) to mitigate those risks.
  4. Implement the necessary policies and procedures to support the controls.
  5. Conduct regular tests and audits to make sure the controls are working as intended.
  6. Review, report and update your plans regularly.
  7. 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.

Related articles on GDPR and ISO 27k

The GDPR and Personal Data…HELP! from Cloud Security Alliance




Tags: gdpr, gdpr compliance


Sep 27 2017

Data flow mapping under the EU GDPR

Category: data security,GDPR,Security ComplianceDISC @ 8:56 am

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.

 

Order Today

 





Tags: data flow mapping, data privacy, data security, gdpr


Aug 11 2017

GDPR Documentation Toolkit and gap assessment tool

Category: GDPR,IT Governance,Security ComplianceDISC @ 10:46 am

Data Protection / EU GDPR Toolkits

 

Use this gap assessment tool to:

  • Quickly identify your GDPR compliance gaps
  • Plan and prioritize your GDPR project

EU GDPR Compliance Gap Assessment Tool

 

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.

EU General Data Protection Regulation (GDPR) Documentation Toolkit






Aug 09 2017

EU GDPR: Does my organization need to comply?

Category: GDPR,Security ComplianceDISC @ 9:36 am

By Chloe Biscoe

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

EU GDPR & EU-US Privacy Shield – A Pocket GuideAugust’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.

Alan Calder’s EU GDPR & EU-US Privacy Shield – A Pocket Guide explains in simple terms:

  • The terms and definitions used within the GDPR and the EU-US Privacy Shield
  • The key requirements
  • How to comply with the Regulation

 

Data Protection / EU GDPR Toolkits

 





Jul 12 2025

Why Integrating ISO Standards is Critical for GRC in the Age of AI

Category: AI,GRC,Information Security,ISO 27k,ISO 42001disc7 @ 9:56 am

Integrating ISO standards across business functions—particularly Governance, Risk, and Compliance (GRC)—has become not just a best practice but a necessity in the age of Artificial Intelligence (AI). As AI systems increasingly permeate operations, decision-making, and customer interactions, the need for standardized controls, accountability, and risk mitigation is more urgent than ever. ISO standards provide a globally recognized framework that ensures consistency, security, quality, and transparency in how organizations adopt and manage AI technologies.

In the GRC domain, ISO standards like ISO/IEC 27001 (information security), ISO/IEC 38500 (IT governance), ISO 31000 (risk management), and ISO/IEC 42001 (AI management systems) offer a structured approach to managing risks associated with AI. These frameworks guide organizations in aligning AI use with regulatory compliance, internal controls, and ethical use of data. For example, ISO 27001 helps in safeguarding data fed into machine learning models, while ISO 31000 aids in assessing emerging AI risks such as bias, algorithmic opacity, or unintended consequences.

The integration of ISO standards helps unify siloed departments—such as IT, legal, HR, and operations—by establishing a common language and baseline for risk and control. This cohesion is particularly crucial when AI is used across multiple departments. AI doesn’t respect organizational boundaries, and its risks ripple across all functions. Without standardized governance structures, businesses risk deploying fragmented, inconsistent, and potentially harmful AI systems.

ISO standards also support transparency and accountability in AI deployment. As regulators worldwide introduce new AI regulations—such as the EU AI Act—standards like ISO/IEC 42001 help organizations demonstrate compliance, build trust with stakeholders, and prepare for audits. This is especially important in industries like healthcare, finance, and defense, where the margin for error is small and ethical accountability is critical.

Moreover, standards-driven integration supports scalability. As AI initiatives grow from isolated pilot projects to enterprise-wide deployments, ISO frameworks help maintain quality and control at scale. ISO 9001, for instance, ensures continuous improvement in AI-supported processes, while ISO/IEC 27017 and 27018 address cloud security and data privacy—key concerns for AI systems operating in the cloud.

AI systems also introduce new third-party and supply chain risks. ISO standards such as ISO/IEC 27036 help in managing vendor security, and when integrated into GRC workflows, they ensure AI solutions procured externally adhere to the same governance rigor as internal developments. This is vital in preventing issues like AI-driven data breaches or compliance gaps due to poorly vetted partners.

Importantly, ISO integration fosters a culture of risk-aware innovation. Instead of slowing down AI adoption, standards provide guardrails that enable responsible experimentation and faster time to trust. They help organizations embed privacy, ethics, and accountability into AI from the design phase, rather than retrofitting compliance after deployment.

In conclusion, ISO standards are no longer optional checkboxes; they are strategic enablers in the age of AI. For GRC leaders, integrating these standards across business functions ensures that AI is not only powerful and efficient but also safe, transparent, and aligned with organizational values. As AI’s influence grows, ISO-based governance will distinguish mature, trusted enterprises from reckless adopters.

The Strategic Synergy: ISO 27001 and ISO 42001 – A New Era in Governance

ISO 42001 Readiness: A 10-Step Guide to Responsible AI Governance

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Historical data on the number of ISO/IEC 27001 certifications by country across the Globe

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Download ISO27000 family of information security standards today!

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What does BS ISO/IEC 42001 – Artificial intelligence management system cover?
BS ISO/IEC 42001:2023 specifies requirements and provides guidance for establishing, implementing, maintaining and continually improving an AI management system within the context of an organization.

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ISO/IEC 42001:2023 – from establishing to maintain an AI management system.

ISO/IEC 27701 2019 Standard – Published in August of 2019, ISO 27701 is a new standard for information and data privacy. Your organization can benefit from integrating ISO 27701 with your existing security management system as doing so can help you comply with GDPR standards and improve your data security.

Check out our earlier posts on the ISO 27000 series.

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Tags: AIMS, isms, iso 27000


Jul 11 2025

The Hidden Dangers of AI: Why Data Security Can’t Be an Afterthought

Category: AI,data securitydisc7 @ 9:18 am

1. The Rise of AI and the Data Dilemma
Artificial intelligence (AI) is revolutionizing industries, enabling faster decisions and improved productivity. However, its exponential growth is outpacing efforts to ensure data protection and security. The integration of AI into critical infrastructure and business systems introduces new vulnerabilities, particularly as vast amounts of sensitive data are used for training models.

2. AI as Both Solution and Threat
AI offers great potential for threat detection and prevention, yet it also presents new risks. Threat actors are exploiting AI tools to create sophisticated cyberattacks, such as deepfakes, phishing campaigns, and automated intrusion tactics. This dual-use nature of AI complicates its adoption and regulation.

3. Data Privacy in the Age of AI
AI systems often rely on massive datasets, which can include personally identifiable information (PII). Improper handling or insufficient anonymization of data poses privacy risks. Regulators and organizations are increasingly concerned with how data is collected, stored, and used within AI systems, as breaches or misuse can lead to severe legal and reputational consequences.

4. Regulatory Pressure and Gaps
Governments and regulatory bodies are rushing to catch up with AI advancements. While frameworks like GDPR and the AI Act (in the EU) aim to govern AI use, there remains a lack of global standardization. The absence of unified policies leaves organizations vulnerable to compliance gaps and fragmented security postures.

5. Shadow AI and Organizational Blind Spots
One emerging challenge is the rise of “shadow AI”—tools and models used without official oversight or governance. Employees may experiment with AI tools without understanding the associated risks, leading to data leaks, IP exposure, and compliance violations. This shadow usage exacerbates existing security blind spots.

6. Vulnerable Supply Chains
AI systems often depend on third-party tools, open-source models, and external data sources. This complex supply chain introduces additional risks, as vulnerabilities in any component can compromise the entire system. Supply chain attacks targeting AI infrastructure are becoming more common and harder to detect.

7. Security Strategies Lag Behind AI Adoption
Despite the growing risks, many organizations still treat AI security reactively rather than proactively. Traditional cybersecurity frameworks may not be sufficient to protect dynamic AI systems. There’s a pressing need to embed security into AI development and deployment processes, including model integrity checks and data governance protocols.

8. Building Trust in AI Requires Transparency and Collaboration
To address these challenges, organizations must foster transparency, cross-functional collaboration, and continuous monitoring of AI systems. It’s essential to align AI innovation with ethical practices, robust governance, and security-by-design principles. Trustworthy AI must be both functional and safe.


Opinion:
The article accurately highlights a growing paradox in the AI space—innovation is moving at breakneck speed, while security and governance lag dangerously behind. In my view, this imbalance could undermine public trust in AI if not corrected swiftly. Organizations must treat AI as a high-stakes asset, not just a tool. Proactively securing data pipelines, monitoring AI behaviors, and setting strict access controls are no longer optional—they are essential pillars of responsible innovation. Investing in data governance and AI security now is the only way to ensure its benefits outweigh the risks.

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Tags: Dangers of AI, The Hidden Dangers of AI


Jul 10 2025

Why Smart Businesses Are Investing in Data Governance Now

Category: AI,Data Governance,IT Governancedisc7 @ 9:11 am

  1. The global data governance market is on a strong upward trajectory and is expected to reach $9.62 billion by 2030. This growth is fueled by an evolving business landscape where data is at the heart of decision-making and operations. As organizations recognize the strategic value of data, governance has shifted from a technical afterthought to a business-critical priority.
  2. The demand surge is largely attributed to increased regulatory pressure, including global mandates like ISO 27001, ISO 42001, ISO 27701, GDPR and CCPA, which require organizations to manage personal data responsibly. Simultaneously, companies face mounting obligations to demonstrate compliance and accountability in their data handling practices.
  3. The exponential growth in data volumes, driven by digital transformation, IoT, and cloud adoption, has added complexity to data environments. Enterprises now require sophisticated frameworks to ensure data accuracy, accessibility, and security throughout its lifecycle.
  4. Highly regulated sectors such as finance, insurance, and healthcare are leading the charge in governance investments. For these industries, maintaining data integrity is not just about compliance—it’s also about building trust with customers and avoiding operational and reputational risks.
  5. Looking back, the data governance market was valued at just $1.3 billion in 2015. Over the past decade, cyber threats, cloud adoption, and the evolving regulatory climate have dramatically reshaped how organizations view data control, privacy, and stewardship.
  6. Governance is no longer a luxury—it’s an operational necessity. Businesses striving to scale and innovate recognize that a lack of governance leads to data silos, inconsistent reporting, and increased exposure to risk. As a result, many are embedding governance policies into their digital strategy and enterprise architecture.
  7. The focus on data governance is expected to intensify over the next five years. Emerging trends such as AI governance, real-time data lineage, and automation in compliance management will shape the next generation of tools and frameworks. As organizations increasingly adopt data mesh and decentralized architectures, governance solutions will need to be more agile, scalable, and intelligent to meet modern demands.

Data Governance Market Progression (Next 5 Years):

The next five years will see data governance evolve into a more intelligent, automated, and embedded function within digital enterprises. Expect the market to expand across small and mid-sized businesses, not just large enterprises, driven by affordable SaaS solutions and frameworks tailored to industry-specific needs. Additionally, AI and machine learning will become central to governance platforms, enabling predictive policy enforcement, automated classification, and real-time anomaly detection. With the increasing use of generative AI, data lineage and auditability will gain prominence. Overall, governance will move from being reactive to proactive, adaptive, and risk-focused, aligning closely with broader ESG (Environmental, Social, and Governance factors) and data ethics initiatives.

📘 Data Governance Guidelines Outline

1. Define Objectives and Scope

  • Align governance with business goals (e.g., compliance, quality, security).
  • Identify which data domains and systems are in scope.
  • Establish success metrics (e.g., reduced errors, compliance rate).

2. Establish Governance Roles and Responsibilities

  • Data Owners – accountable for data quality and policies.
  • Data Stewards – responsible for day-to-day data management.
  • Data Governance Council – oversees strategy and conflict resolution.
  • IT/Data Teams – implement and support governance tools and policies.

3. Create Data Policies and Standards

  • Data classification (e.g., PII, confidential, public).
  • Access control and data usage policies.
  • Data retention and archival rules.
  • Naming conventions, metadata standards, and documentation guidelines.

4. Ensure Data Quality Management

  • Define data quality dimensions: accuracy, completeness, timeliness, consistency, validity.
  • Use profiling tools to monitor and report data quality issues.
  • Set up data cleansing and remediation processes.

5. Implement Data Security and Privacy Controls

  • Align with frameworks like ISO 27001, NIST, and GDPR/CCPA.
  • Encrypt sensitive data in transit and at rest.
  • Conduct privacy impact assessments (PIAs).
  • Establish audit trails and logging mechanisms.

6. Enable Data Lineage and Transparency

  • Document data sources, transformations, and flows.
  • Maintain a centralized data catalog.
  • Support traceability for compliance and analytics.

7. Provide Training and Change Management

  • Educate stakeholders on governance roles and data handling practices.
  • Promote a data-driven culture.
  • Communicate changes in policies and ensure adoption.

8. Measure, Monitor, and Improve

  • Track key performance indicators (KPIs).
  • Conduct regular audits and maturity assessments.
  • Review and update governance policies annually or when business needs change.

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Tags: Data Governance


Jul 02 2025

 ISO/IEC 42001:2023 – from establishing to maintain an AI management system

Category: AIdisc7 @ 12:06 pm

AI businesses are at risk due to growing cyber threats, regulatory pressure, and ethical concerns. They often process vast amounts of sensitive data, making them prime targets for breaches and data misuse. Malicious actors can exploit AI systems through model manipulation, adversarial inputs, or unauthorized access. Additionally, lack of standardized governance and compliance frameworks exposes them to legal and reputational damage. As AI adoption accelerates, so do the risks.

AI businesses are at risk because they often handle large volumes of sensitive data, rely on complex algorithms that may be vulnerable to manipulation, and operate in a rapidly evolving regulatory landscape. Threats include data breaches, model poisoning, IP theft, bias in decision-making, and misuse of AI tools by attackers. Additionally, unclear accountability and lack of standardized AI security practices increase their exposure to legal, reputational, and operational risks.

Why it matters

It matters because the integrity, security, and trustworthiness of AI systems directly impact business reputation, customer trust, and regulatory compliance. A breach or misuse of AI can lead to financial loss, legal penalties, and harm to users. As AI becomes more embedded in critical decision-making—like healthcare, finance, and security—the risks grow more severe. Ensuring responsible and secure AI isn’t just good practice—it’s essential for long-term success and societal trust.

To reduce risks in AI businesses, we can:

  1. Implement strong governance with AIMS – Define clear accountability, policies, and oversight for AI development and use.
  2. Secure data and models – Encrypt sensitive data, restrict access, and monitor for tampering or misuse.
  3. Conduct risk assessments – Regularly evaluate threats, vulnerabilities, and compliance gaps in AI systems.
  4. Ensure transparency and fairness – Use explainable AI and audit algorithms for bias or unintended consequences.
  5. Stay compliant – Align with evolving regulations like GDPR, NIST AI RMF, or the EU AI Act.
  6. Train teams – Educate employees on AI ethics, security best practices, and safe use of generative tools.

Proactive risk management builds trust, protects assets, and positions AI businesses for sustainable growth.

 ISO/IEC 42001:2023 – from establishing to maintain an AI management system (AIMS)

BSI ISO 31000 is standard for any organization seeking risk management guidance

ISO/IEC 27001 and ISO/IEC 42001, both standards address risk and management systems, but with different focuses. ISO/IEC 27001 is centered on information security—protecting data confidentiality, integrity, and availability—while ISO/IEC 42001 is the first standard designed specifically for managing artificial intelligence systems responsibly. ISO/IEC 42001 includes considerations like AI-specific risks, ethical concerns, transparency, and human oversight, which are not fully addressed in ISO 27001. Organizations working with AI should not rely solely on traditional information security controls.

While ISO/IEC 27001 remains critical for securing data, ISO/IEC 42001 complements it by addressing broader governance and accountability issues unique to AI. The article suggests that companies developing or deploying AI should integrate both standards to build trust and meet growing stakeholder and regulatory expectations. Applying ISO 42001 can help demonstrate responsible AI practices, ensure explainability, and mitigate unintended consequences, positioning organizations to lead in a more regulated AI landscape.

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Tags: AIMS, ISO 42001, ISO/IEC 42001


Jun 28 2025

Vineyard and Wineries may be at Risk

1. Vineyard and Wineries are increasingly at Risk

Many winery owners and executives—particularly those operating small to mid-sized, family-run estates—underestimate their exposure to cyber threats. Yet with the rise of direct-to-consumer channels like POS systems, wine clubs, and ecommerce platforms, these businesses now collect and store sensitive customer and employee data, including payment details, birthdates, and Social Security numbers. This makes them attractive targets for cybercriminals.

The Emerging Threat of Cyber-Physical Attacks

Wineries increasingly rely on automated production systems and IoT sensors to manage fermentation, temperature control, and chemical dosing. These digital tools can be manipulated by hackers to:

  • Disrupt production by altering temperature or chemical settings.
  • Spoil inventory through false sensor data or remote tampering.
  • Undermine trust by threatening product safety and quality.

A Cautionary Tale

While there are no public reports of terrorist attacks on the wine industry’s supply chain, the 1985 Austrian wine scandal is a stark reminder of what can happen when integrity is compromised. In that case, wine was adulterated with antifreeze (diethylene glycol) to manipulate taste—resulting in global recalls, destroyed reputations, and public health risks.

The lesson is clear: cyber and physical safety in the winery business are now deeply intertwined.


2. Why Vineyards and Wineries Are at Risk

  • High-value data: Personal and financial details stored in club databases or POS systems can be exploited and sold on the dark web.
  • Legacy systems & limited expertise: Many wineries rely on outdated IT infrastructure and lack in-house cybersecurity staff.
  • Regulatory complexity: Compliance with data privacy regulations like CCPA/CPRA adds to the burden, and gaps can lead to penalties.
  • Charming targets: Boutique and estate brands, which often emphasize hospitality and trust, can be unexpectedly appealing to attackers seeking vulnerable entry points.

3. Why It Matters

  • Reputation risk: A breach can shatter consumer trust—especially among affluent wine club customers who expect discretion and reliability.
  • Financial & legal exposure: Incidents may invite steep fines, ransomware costs, and lawsuits under privacy laws.
  • Operational disruption: Outages or ransomware can cripple point-of-sale and club systems, causing revenue loss and logistical headaches.
  • Competitive advantage: Secure operations can boost customer confidence, support audit and M&A readiness, and unlock better insurance or investor opportunities.

4. What You Can Do About It

  • Risk & compliance assessment: Discover vulnerabilities in systems, Wi‑Fi, and employee habits. Score your risk with a 10-page report for stakeholders.
  • Privacy compliance support: Navigate CCPA/CPRA (and PCI/GDPR as needed) to keep your winery legally sound.
  • Defense against phishing & ransomware: Conduct employee training, simulations, and implement defenses.
  • Security maturity roadmap: Prioritize improvements—like endpoint protection, firewalls, 2FA setups—and phase them according to your brand and budget.
  • Fractional vCISO support: Access quarterly executive consultations to align compliance and tech strategy without hiring full-time experts.
  • Optional services: Pen testing, PCI-DSS support, vendor reviews, and business continuity planning for deeper security.

DISC WinerySecure™ offers a tailored roadmap to safeguard your winery:

You don’t need to face this alone. We offer Free checklist + consultation.

DISC InfoSec
Virtual CISO | Wine Industry Security & Compliance

 Info@deurainfosec.com | https://www.deurainfosec.com/ | (707) 998-5164 | Contact us


Investing in a proactive security strategy isn’t just about avoiding threats—it’s about protecting your brand, securing compliance, and empowering growth. Contact DISC WinerySecure™ today for a free consultation.

In addition to winery protection, DISC specializes in securing data during mergers and acquisitions.

DISC WinerySecure™: Cybersecurity & Compliance Services for California Wineries


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 | InfoSec books | Follow our blog | DISC llc is listed on The vCISO Directory | ISO 27k Chat bot | Comprehensive vCISO Services | ISMS Services | Security Risk Assessment Services | Mergers and Acquisition Security

Next Steps: Let us prepare a customized scorecard or walk you through a free 15-minute discovery call.

Contact: info@discinfosec.com | www.discinfosec.com

Tags: Vineyard, Wineries at Risk


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