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Data Security

Article 32

Taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, 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:

A frame work for data security

Plan for data breach and have a policy and procedure

  • Notification of breaches will be compulsory!
  • Notification to the ICO unless unlikely to result in a risk to the rights and freedoms of individual
  • Notification to the individual where high risk to their rights and freedoms e.g.: discrimination, identity, theft or fraud
  • Must be notified to ICO within 72 hours ( not business hours)
  • Identify type of data
  • Cause of breach
  • Remedial action

Security Frame work designed to provide

  • 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.

Data Security – basic steps - company house keeping

CONFIRM AND REVIEW POLICIES ON

  • Passwords
  • Two Factor authentication
  • Up to date Anti virus software
  • Malware and e mail awareness training
  • Restricted personal use of company machines
  • Data architecture
  • Encrypt data on PC
  • Secure back up of data

Within the information you hold, where does paper fit in to your GDPR controls?

  • Personal identifiable Information location
  • Access controls
  • Usage controls
  • Digital storage and architecture
  • Lawful retention
  • Individual document identifiers
  • Printing control
  • Breech policy

In considering the Information you hold: Reducing paper breaches
Data Privacy Impact Assessment of paper which holds PII

  • DPIA is required where the processing is “likely to result in a high risk to rights and freedoms” of individuals
  • Access controls
  • Security framework
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