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.
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.
In this promotion the second course exam is completely FREE OF CHARGE.
The bundles are displayed on two landing pages, one with bundles related to ISO 9001 and another with bundles related to ISO 27001.
Foundations course exam bundles:
ISO 9001 Foundations exam + ISO 14001 Foundation exam
ISO 9001 Foundations exam + ISO 27001 Foundation exam
ISO 9001 Foundations exam + ISO 13485 Foundation exam
ISO 9001 Foundations exam + ISO 45001 Foundation exam
ISO 14001 Foundations exam + ISO 45001 Foundation exam
Internal Auditor course exam bundles:
ISO 9001 Internal Auditor exam + ISO 14001 Internal Auditor exam
ISO 9001 Internal Auditor exam + ISO 27001 Internal Auditor exam
ISO 9001 Internal Auditor exam + ISO 13485 Internal Auditor exam
ISO 9001 Internal Auditor exam + ISO 45001 Internal Auditor exam
ISO 14001 Internal Auditor exam + ISO 45001 Internal Auditor exam
Lead Auditor course exam bundles:
ISO 9001 Lead Auditor exam + ISO 14001 Lead Auditor exam
ISO 9001 Lead Auditor exam + ISO 13485 Lead Auditor exam
ISO 9001 Lead Auditor exam + ISO 45001 Lead Auditor exam
ISO 14001 Lead Auditor exam + ISO 45001 Lead Auditor exam
Lead Implementer course exam bundles:
ISO 9001 Lead Implementer exam + ISO 14001 Lead Implementer exam
ISO 9001 Lead Implementer exam + ISO 13485 Lead Implementer exam
ISO 9001 Lead Implementer exam + ISO 45001 Lead Implementer exam
ISO 14001 Lead Implementer exam + ISO 45001 Lead Implementer exam
2/ ISO 27001/EU GDPR-related bundles:
ISO 27001 Foundations exam + EU GDPR Foundations exam
ISO 27001 Foundations exam + ISO 9001 Foundation exam
ISO 27001 Internal Auditor exam + EU GDPR Data Protection Officer exam
ISO 27001 Internal Auditor exam + ISO 9001 Internal Auditor exam
ISO 27001 Lead Auditor exam + ISO 9001 Lead Auditor exam
ISO 27001 Lead Implementer exam + ISO 9001 Lead Implementer exam
Take ISO 27001 course exam and get the EU GDPR course exam for Free
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.
Chief Information Security Officers (CISOs) hold a critical and challenging role in today’s rapidly evolving cybersecurity landscape. Here are the common security challenges CISOs face.
As organizations increasingly rely on technology to drive their operations, CISOs face complex security challenges that demand their expertise and strategic decision-making.
These challenges arise from the constant emergence of sophisticated cyber threats, the need to protect sensitive data, and the ever-evolving regulatory landscape.
The role of a CISO requires balancing proactive risk mitigation with the ability to respond swiftly to incidents and breaches.
This article will delve into the top challenges CISOs face, including protecting digital assets, managing security incidents, ensuring compliance, dealing with insider threats, and the relentless pursuit of cyber resilience.
By understanding these challenges, CISOs can develop robust cybersecurity strategies and lead their organizations toward a secure and resilient future.
Who is a CISO?
Chief Information Security Officer (CISO) is a senior executive responsible for overseeing and administering an organization’s information security plan.
A CISO’s primary responsibility is safeguarding the confidentiality, availability, and integrity of an organization’s information assets and systems.
They are accountable for creating and enforcing strategies, policies, and procedures to defend against cyber threats, protect sensitive data, and mitigate security risks.
CISOs play a crucial role in maintaining an organization’s security posture by establishing and enforcing security standards, conducting risk assessments, and implementing appropriate security controls.
They collaborate with other executives, IT teams, and stakeholders to align security initiatives with business objectives and ensure that security measures are integrated into the organization’s operations.
In addition to their technical expertise, CISOs often engage in risk management, incident response planning, security awareness training, and compliance with regulatory requirements.
They stay updated on the latest cybersecurity trends, threats, and technologies to address emerging risks and implement appropriate security measures effectively.
The role of a CISO has become increasingly important as cyber threats evolve in complexity and frequency.
CISOs are responsible for safeguarding the organization’s sensitive information, maintaining the trust of customers and stakeholders, and ensuring business continuity in the face of cybersecurity challenges.
What are all the Roles and Responsibilities of CISO?
Developing and Implementing Information Security Strategy: The CISO is responsible for developing and implementing an overarching information security strategy aligned with the organization’s business objectives. This includes setting security goals, defining security policies and procedures, and establishing risk management frameworks.
Leading the Security Team: The CISO manages and provides leadership to the security team, including hiring, training, and supervising security personnel. They ensure the team has the necessary skills, resources, and support to carry out their responsibilities effectively.
Overseeing Security Operations: The CISO oversees day-to-day security operations, including incident response, vulnerability management, threat intelligence, and security monitoring. They ensure appropriate controls, technologies, and processes are in place to protect the organization’s assets.
Risk Management: The CISO is responsible for identifying and assessing security risks to the organization’s information systems and assets. They develop and implement risk management strategies to safeguard critical data and systems, including risk mitigation, transfer, and acceptance.
Compliance and Regulatory Requirements: The CISO ensures that the organization complies with relevant security regulations, industry standards, and legal requirements. They stay updated on emerging regulations and ensure appropriate controls and processes are in place to meet compliance obligations.
Security Incident Response: The CISO leads the organization’s response to security incidents, including data breaches, malware attacks, and other security breaches. They establish incident response plans, coordinate efforts, and collaborate with relevant stakeholders, such as legal, PR, and law enforcement agencies.
Security Awareness and Training: The CISO promotes a culture of security awareness throughout the organization. They develop and deliver security awareness programs and training initiatives to educate employees on security best practices and minimize human-related security risks.
Vendor and Third-Party Risk Management: The CISO assesses and manages security risks associated with third-party vendors and partners. They establish vendor security requirements, conduct due diligence, and monitor compliance with security standards and contractual obligations.
Security Governance and Reporting: The CISO provides regular reports and updates on the organization’s security posture to executive management, board members, and other relevant stakeholders. They ensure that security metrics and key performance indicators (KPIs) are established to measure the effectiveness of security programs.
Incident Investigation and Forensics: In the event of security incidents, the CISO oversees the investigation and forensic analysis to identify the root cause, assess the impact, and prevent future occurrences. As required, they collaborate with internal and external resources, such as forensic experts and law enforcement agencies.
Security Challenges CISOs Face
CISOs face various common security challenges as they strive to protect their organizations’ digital assets and information. Perimeter 81 Guide helps CISOs to prevent their network from being at Risk. Some of the key challenges they encounter include:
Sophisticated Cyberattacks: CISOs must defend against increasingly sophisticated cyber threats, including advanced persistent threats (APTs), ransomware attacks, social engineering, and zero-day exploits. These attacks can bypass traditional security measures and require constant vigilance and adaptive security strategies.
Insider Threats: CISOs need to address the risks posed by insiders, including employees, contractors, or partners who have authorized access to systems and data. Insider threats can involve accidental data breaches, negligence, or malicious intent, requiring a balance between enabling productivity and implementing controls to prevent unauthorized access or data leakage.
Compliance and Regulatory Requirements: CISOs must ensure their organizations comply with industry-specific regulations, such as GDPR, HIPAA, PCI-DSS, or SOX, and evolving privacy laws. Navigating complex compliance requirements and maintaining a robust security posture to meet these standards can be a significant challenge.
Cloud Security: As organizations increasingly adopt cloud services and infrastructure, CISOs must address the unique security challenges associated with cloud computing. This includes securing data stored in the cloud, managing access controls, and ensuring the security of cloud service providers (CSPs) and their environments.
Security Skills Gap: CISOs often need more skilled cybersecurity professionals. The industry’s rapid growth and evolving threat landscape have resulted in high demand for cybersecurity talent, making recruiting and retaining qualified professionals challenging.
Third-Party Risk: Organizations rely on third-party vendors and suppliers, introducing potential security risks. CISOs must assess the security posture of third parties, establish contractual security obligations, and monitor their adherence to security standards to mitigate the risk of breaches through these external connections.
Security Awareness and Training: Human error remains a significant factor in cybersecurity incidents. CISOs must promote a strong security culture, provide regular training and awareness programs, and educate employees about cybersecurity best practices to minimize the risk of social engineering, phishing attacks, and other user-related vulnerabilities.
Incident Response and Recovery: CISOs must develop and test robust incident response plans to manage and recover from security incidents effectively. This involves identifying and containing breaches, conducting forensic investigations, and implementing remediation measures to minimize the impact and prevent future incidents.
Emerging Technologies: Adopting technologies like the Internet of Things (IoT), artificial intelligence (AI), and blockchain introduces new security challenges. CISOs must understand the security implications of these technologies, assess risks, and implement appropriate controls to protect against potential vulnerabilities and attacks.
Budget and Resource Constraints: CISOs often face budget limitations and the need to prioritize security initiatives. Balancing the allocation of resources to address immediate security needs while investing in long-term security capabilities can be a significant challenge.
Data breach notification requirements are complex in the US, with various federal and state laws containing different requirements for when security incidents must be disclosed.
Some even have substantially different definitions for what a ‘data breach’ or ‘personal data’ is.
As such, it can be hard to know whether you need to report an incident, let alone how you should go about it.
We address these issues in this blog, bringing some much-needed clarity to the subject.
State laws on data breach notification
There is no single set of data protection laws in the U.S., with the rules instead comprised of a patchwork of industry-specific federal laws and state legislation.
To complicate matters further, several states have created new laws in recent years to bolster data protection requirements. For instance, New York has created the SHIELD Act, while Colorado and California have both created data privacy legislation.
Elsewhere, the U.S. government is attempting to unify data protection requirements with its National Cybersecurity Strategy.
The decision to revise data protection laws follows the introduction of the EU GDPR (General Data Protection Regulation) in 2018, which radically shifted organizations’ requirements.
Organizations in the U.S. that process EU residents’ personal data are required to comply with the GDPR, and those that conduct business across state lines will face similar compliance challenges.
The GDPR is particularly important here, because many organizations in the U.S. assume that it only applies in the EU. However, its requirements apply to any organization that processes EU residents’ personal data, which is particularly common for organizations that have an online presence.
GDPR compliance is also helpful for managing patchwork of U.S. data protection legislations. Its requirements are far stricter than any domestic laws, so achieving GDPR compliance will cover you for a range of other requirements.
This free guide explains how and when the GDPR applies in the U.S. and the steps you can take to ensure your organization meets its transatlantic data processing practices.
You’ll also learn about the Regulation’s core principles and data subject rights, and the benefits of GDPR compliance.
We also provide tips on how to write your data privacy notice and give you tips on how to further your understanding of its compliance requirements.
Your data is an asset. Safeguarding it will help you comply with data protection laws and allow your business to thrive
A global leader in privacy guidance, audits, tools, training and software
IT Governance is a market leader in data privacy and cyber security solutions. Their broad suite of offerings is one of the most comprehensive in the world.
ITG affordable solutions have assisted numerous individuals and organizations in understanding the tangible aspects of data privacy. With substantial legal and technical proficiency, coupled with a 15-year history in cybersecurity risk management, ITG customers have complete confidence in entrusting us with their needs.
Speed up your compliance initiatives for GDPR, CPRA, and other regulations ISO 27701 by utilizing ITG collection of top-performing Tools, Templates and eBooks.
ISO 27701 is an international standard that provides guidelines for implementing a privacy information management system (PIMS) based on the requirements of the General Data Protection Regulation (GDPR) and other relevant privacy regulations. It was published by the International Organization for Standardization (ISO) in August 2019.
ISO 27701 is an extension of ISO 27001, which is a widely recognized international standard for information security management. It introduces additional controls and requirements specific to the management of privacy information within an organization.
The standard outlines the framework for establishing, implementing, maintaining, and continually improving a privacy information management system. It helps organizations to identify and manage privacy risks, implement privacy controls, and demonstrate compliance with applicable privacy laws and regulations.
ISO 27701 focuses on protecting individuals’ privacy rights and ensuring responsible handling of personal information. It provides guidance on various aspects of privacy management, including privacy policy development, privacy risk assessment, privacy impact assessments, consent management, data subject rights, data breach management, and vendor management.
By implementing ISO 27701, organizations can enhance their privacy practices, build trust with customers and partners, and demonstrate their commitment to protecting personal information. It is especially relevant for organizations that process large amounts of personal data or handle sensitive information, as it helps them establish a systematic approach to privacy management.
It’s important to note that ISO 27701 is not a certification itself but an extension to ISO 27001. Organizations can seek certification against ISO 27001 and include ISO 27701 requirements as part of their certification process to demonstrate compliance with privacy regulations.
in what situation ISO 27701 certification may be appropriate?
ISO 27701 certification may be appropriate for organizations that handle personal data and are subject to privacy regulations such as the General Data Protection Regulation (GDPR) in the European Union or other similar privacy laws worldwide. Here are some situations where ISO 27701 certification may be relevant:
Data Controllers and Processors: Organizations that act as data controllers or processors and handle personal data on a significant scale can benefit from ISO 27701 certification. This includes organizations in sectors such as healthcare, finance, e-commerce, technology, and marketing that process large volumes of personal information.
Legal and Regulatory Compliance: ISO 27701 certification helps organizations demonstrate compliance with privacy regulations. If an organization operates in jurisdictions with strict privacy laws or serves customers from regions with robust privacy requirements, certification can provide assurance to stakeholders that the organization has implemented appropriate privacy controls.
Third-Party Assurance: Organizations that act as vendors or service providers for other companies may pursue ISO 27701 certification to demonstrate their commitment to privacy management. This can be particularly relevant for organizations providing cloud services, data processing, or other services involving personal data, as it helps build trust and confidence with customers.
Competitive Advantage: ISO 27701 certification can serve as a competitive differentiator for organizations. It showcases their dedication to privacy protection and can attract customers who prioritize strong privacy practices and compliance when selecting vendors or partners.
Data Breach Prevention and Response: ISO 27701 provides guidelines for managing data breaches and responding to privacy incidents effectively. Organizations that want to establish robust incident response procedures and enhance their ability to prevent and manage data breaches can benefit from implementing ISO 27701.
Privacy-Driven Culture: ISO 27701 certification promotes a privacy-centric culture within an organization. It helps organizations establish clear policies, procedures, and training programs to educate employees about privacy responsibilities and foster a privacy-aware mindset throughout the organization.
Ultimately, the decision to pursue ISO 27701 certification depends on the specific needs, risk profile, and regulatory environment of the organization. Conducting a thorough assessment of privacy risks, legal requirements, and business objectives can help determine whether certification is appropriate and beneficial for the organization.
Achieve full compliance with ISO 27701:2019
The ISO 27701 Gap Analysis Tool has been created to help organizations identify whether they are meeting the requirements of the Standard and where they are falling short. Note that this tool assumes that you have a complete and functioning ISO 27001:2013 ISMS (information security management system).
It helps organizations prioritise work areas in order to expand an existing ISMS to take account of privacy. It also gives organizations direction, helping project managers identify where to start.
This standard is ideal for organizations wishing to implement a PIMS that supports their ISMS objectives and helps meet their data privacy compliance requirements, such as those stipulated by the EU’s GDPR (General Data Protection Regulation) and the UK’s DPA (Data Protection Act) 2018.
We’d love to hear from you! If you have any questions, comments, or feedback, please don’t hesitate to contact us. Our team is here to help and we’re always looking for ways to improve our services. You can reach us by email (info@deurainfosec.com), or through our website’s contact form.
Chief Information Security Officers (CISOs) hold a critical and challenging role in today’s rapidly evolving cybersecurity landscape. Here are the common security challenges CISOs face.
As organizations increasingly rely on technology to drive their operations, CISOs face complex security challenges that demand their expertise and strategic decision-making.
These challenges arise from the constant emergence of sophisticated cyber threats, the need to protect sensitive data, and the ever-evolving regulatory landscape.
The role of a CISO requires balancing proactive risk mitigation with the ability to respond swiftly to incidents and breaches.
This article will delve into the top challenges CISOs face, including protecting digital assets, managing security incidents, ensuring compliance, dealing with insider threats, and the relentless pursuit of cyber resilience.
By understanding these challenges, CISOs can develop robust cybersecurity strategies and lead their organizations toward a secure and resilient future.
Who is a CISO?
Chief Information Security Officer (CISO) is a senior executive responsible for overseeing and administering an organization’s information security plan.
A CISO’s primary responsibility is safeguarding the confidentiality, availability, and integrity of an organization’s information assets and systems.
They are accountable for creating and enforcing strategies, policies, and procedures to defend against cyber threats, protect sensitive data, and mitigate security risks.
CISOs play a crucial role in maintaining an organization’s security posture by establishing and enforcing security standards, conducting risk assessments, and implementing appropriate security controls.
They collaborate with other executives, IT teams, and stakeholders to align security initiatives with business objectives and ensure that security measures are integrated into the organization’s operations.
In addition to their technical expertise, CISOs often engage in risk management, incident response planning, security awareness training, and compliance with regulatory requirements.
They stay updated on the latest cybersecurity trends, threats, and technologies to address emerging risks and implement appropriate security measures effectively.
The role of a CISO has become increasingly important as cyber threats evolve in complexity and frequency.
CISOs are responsible for safeguarding the organization’s sensitive information, maintaining the trust of customers and stakeholders, and ensuring business continuity in the face of cybersecurity challenges.
What are all the Roles and Responsibilities of CISO?
Developing and Implementing Information Security Strategy: The CISO is responsible for developing and implementing an overarching information security strategy aligned with the organization’s business objectives. This includes setting security goals, defining security policies and procedures, and establishing risk management frameworks.
Leading the Security Team: The CISO manages and provides leadership to the security team, including hiring, training, and supervising security personnel. They ensure the team has the necessary skills, resources, and support to carry out their responsibilities effectively.
Overseeing Security Operations: The CISO oversees day-to-day security operations, including incident response, vulnerability management, threat intelligence, and security monitoring. They ensure appropriate controls, technologies, and processes are in place to protect the organization’s assets.
Risk Management: The CISO is responsible for identifying and assessing security risks to the organization’s information systems and assets. They develop and implement risk management strategies to safeguard critical data and systems, including risk mitigation, transfer, and acceptance.
Compliance and Regulatory Requirements: The CISO ensures that the organization complies with relevant security regulations, industry standards, and legal requirements. They stay updated on emerging regulations and ensure appropriate controls and processes are in place to meet compliance obligations.
Security Incident Response: The CISO leads the organization’s response to security incidents, including data breaches, malware attacks, and other security breaches. They establish incident response plans, coordinate efforts, and collaborate with relevant stakeholders, such as legal, PR, and law enforcement agencies.
Security Awareness and Training: The CISO promotes a culture of security awareness throughout the organization. They develop and deliver security awareness programs and training initiatives to educate employees on security best practices and minimize human-related security risks.
Vendor and Third-Party Risk Management: The CISO assesses and manages security risks associated with third-party vendors and partners. They establish vendor security requirements, conduct due diligence, and monitor compliance with security standards and contractual obligations.
Security Governance and Reporting: The CISO provides regular reports and updates on the organization’s security posture to executive management, board members, and other relevant stakeholders. They ensure that security metrics and key performance indicators (KPIs) are established to measure the effectiveness of security programs.
Incident Investigation and Forensics: In the event of security incidents, the CISO oversees the investigation and forensic analysis to identify the root cause, assess the impact, and prevent future occurrences. As required, they collaborate with internal and external resources, such as forensic experts and law enforcement agencies.
Security Challenges CISOs Face
CISOs face various common security challenges as they strive to protect their organizations’ digital assets and information. Perimeter 81 Guide helps CISOs to prevent their network from being at Risk. Some of the key challenges they encounter include:
Sophisticated Cyberattacks: CISOs must defend against increasingly sophisticated cyber threats, including advanced persistent threats (APTs), ransomware attacks, social engineering, and zero-day exploits. These attacks can bypass traditional security measures and require constant vigilance and adaptive security strategies.
Insider Threats: CISOs need to address the risks posed by insiders, including employees, contractors, or partners who have authorized access to systems and data. Insider threats can involve accidental data breaches, negligence, or malicious intent, requiring a balance between enabling productivity and implementing controls to prevent unauthorized access or data leakage.
Compliance and Regulatory Requirements: CISOs must ensure their organizations comply with industry-specific regulations, such as GDPR, HIPAA, PCI-DSS, or SOX, and evolving privacy laws. Navigating complex compliance requirements and maintaining a robust security posture to meet these standards can be a significant challenge.
Cloud Security: As organizations increasingly adopt cloud services and infrastructure, CISOs must address the unique security challenges associated with cloud computing. This includes securing data stored in the cloud, managing access controls, and ensuring the security of cloud service providers (CSPs) and their environments.
Security Skills Gap: CISOs often need more skilled cybersecurity professionals. The industry’s rapid growth and evolving threat landscape have resulted in high demand for cybersecurity talent, making recruiting and retaining qualified professionals challenging.
Third-Party Risk: Organizations rely on third-party vendors and suppliers, introducing potential security risks. CISOs must assess the security posture of third parties, establish contractual security obligations, and monitor their adherence to security standards to mitigate the risk of breaches through these external connections.
Security Awareness and Training: Human error remains a significant factor in cybersecurity incidents. CISOs must promote a strong security culture, provide regular training and awareness programs, and educate employees about cybersecurity best practices to minimize the risk of social engineering, phishing attacks, and other user-related vulnerabilities.
Incident Response and Recovery: CISOs must develop and test robust incident response plans to manage and recover from security incidents effectively. This involves identifying and containing breaches, conducting forensic investigations, and implementing remediation measures to minimize the impact and prevent future incidents.
Emerging Technologies: Adopting technologies like the Internet of Things (IoT), artificial intelligence (AI), and blockchain introduces new security challenges. CISOs must understand the security implications of these technologies, assess risks, and implement appropriate controls to protect against potential vulnerabilities and attacks.
Budget and Resource Constraints: CISOs often face budget limitations and the need to prioritize security initiatives. Balancing the allocation of resources to address immediate security needs while investing in long-term security capabilities can be a significant challenge.
What are the Security Compliance CISO Should Follow
As a Chief Information Security Officer (CISO), there are several security compliance frameworks and regulations that you should consider following, depending on the nature of your organization and its operations. Here are some of the key security compliance frameworks and regulations:
General Data Protection Regulation (GDPR): If your organization deals with the personal data of individuals in the European Union (EU), GDPR sets requirements for the protection, processing, and transfer of personal data. It includes principles for data minimization, consent, data breach notification, and the rights of individuals.
Payment Card Industry Data Security Standard (PCI DSS): PCI DSS applies to organizations that handle credit card information. It sets requirements for securing payment card data, including network security, encryption, access controls, and regular vulnerability assessments.
Health Insurance Portability and Accountability Act (HIPAA): HIPAA applies to organizations in the healthcare industry that handle protected health information (PHI). It establishes requirements for the privacy and security of PHI, including access controls, encryption, risk assessments, and breach notification.
Sarbanes-Oxley Act (SOX): SOX applies to publicly traded companies in the United States. It sets requirements for financial reporting and establishes controls and processes to ensure the accuracy and integrity of financial statements. While not solely focused on security, it includes provisions for protecting financial data.
National Institute of Standards and Technology (NIST) Cybersecurity Framework: The NIST Cybersecurity Framework provides guidelines and best practices for managing cybersecurity risks. It covers risk assessment, security controls, incident response, and continuous monitoring.
ISO 27001: ISO 27001 is an international standard that provides a framework for establishing, implementing, maintaining, and continually improving an information security management system (ISMS). It covers various aspects of information security, including risk management, access controls, incident management, and security awareness.
Federal Information Security Management Act (FISMA): FISMA applies to U.S. federal agencies and sets requirements for securing federal information and systems. It mandates risk assessments, security controls, incident response planning, and continuous monitoring.
Security Challenges CISOs Face to Manage Security Team
Managing a security team as a Chief Information Security Officer (CISO) requires effective leadership, communication, and coordination. Here are some key aspects to consider when managing a security team:
Establish Clear Roles and Responsibilities: Clearly define the roles and responsibilities of each team member to ensure everyone understands their specific duties and areas of expertise. This clarity helps streamline operations and avoid confusion.
Set Goals and Objectives: Define strategic goals and objectives for the security team aligned with the organization’s overall security strategy. Communicate these goals to the team and regularly track progress to ensure everyone is working towards the same objectives.
Provide Guidance and Mentorship: Offer team members guidance, mentorship, and professional development opportunities. Encourage skill development, certifications, and staying up-to-date with the latest security trends and technologies—support team members in their career growth.
Foster Collaboration and Communication: Promote a collaborative and open communication culture within the team. Encourage knowledge sharing, cross-functional collaboration, and effective communication channels. Regular team meetings, brainstorming sessions, and updates are valuable for aligning efforts.
Support Decision-Making: Empower team members to make decisions within their areas of responsibility. Provide guidance and support when needed, but encourage autonomy and ownership in decision-making. Foster an environment where team members feel comfortable taking calculated risks.
Establish Incident Response Procedures: Develop clear incident response procedures and ensure the team is well-prepared to handle security incidents effectively. Conduct regular drills, tabletop exercises, and simulations to test and improve the team’s incident response capabilities.
Stay Informed and Adapt: Stay up-to-date with the latest security threats, industry trends, and best practices. Encourage continuous learning and professional development for the team. Adapt security strategies and measures as the threat landscape evolves.
Collaborate with Other Departments: Work closely with other departments, such as IT, legal, HR, and executive management, to ensure security initiatives are aligned with business objectives and integrated into overall organizational operations. Build relationships and foster a culture of security awareness throughout the organization.
Regularly Evaluate and Improve: Regularly evaluate the team’s performance, processes, and procedures. Collect feedback from team members and stakeholders to identify areas for improvement. Implement changes and adjustments as necessary to enhance the team’s effectiveness and efficiency.
Lead by Example: Demonstrate strong leadership skills, integrity, and a commitment to security best practices. Lead by example in adhering to security policies and procedures. Encourage a positive and supportive work environment.
Final Thoughts
CISOs face many common security challenges as protectors of their organization’s digital assets and information.
From sophisticated cyberattacks and insider threats to compliance requirements and resource constraints, these challenges highlight the complex and evolving nature of the cybersecurity landscape.
CISOs must navigate these challenges by adopting a proactive and strategic approach to security, leveraging advanced technologies, fostering a strong security culture, and collaborating with stakeholders.
To overcome these challenges, CISOs must stay abreast of emerging threats, continuously evaluate and improve their security measures, and prioritize investments in critical security capabilities.
They must also foster strong partnerships with internal teams, third-party vendors, and industry peers to collectively address security challenges and share best practices.
While the security challenges CISOs face may seem daunting, they also present opportunities for innovation and growth.
By effectively addressing these challenges, CISOs can enhance their organizations’ security posture, safeguard critical assets, and instill confidence in customers and stakeholders.
Ultimately, the role of a CISO requires a comprehensive and adaptable approach to cybersecurity, where staying one step ahead of threats and continuously improving security measures are paramount.
By embracing these challenges, CISOs can help shape a secure and resilient future for their organizations in an increasingly interconnected and threat-filled digital landscape.