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Table of contents

If your job is business development and you have accumulated a contact list of potential prospects, you are permitted to write or telephone them without breaching the GDPR, as that would be a legitimate interest for your company. However, you have to make it easy for them to opt out of such communications. For example, include a pre-paid return envelope for stopping further postal communications and a user-friendly process to cease calls.

There are ongoing discussions across the industry about the business of purchasing contact lists, and the collators of such lists should ensure that they have obtained the proper consents from all data subjects. As a purchaser of a list, you would be well advised not to assume that such consents have been sought or granted. A further consideration is that the data subject must have the ability to withdraw consent at any time with constraints of course. Consequently, in your role as a data controller, you have the obligation to maintain auditable records of what the data subjects have consented to historically as well as currently.

Principles II-IV elaborate on the boundaries of what is acceptable in terms of the personal information data controllers hold on data subjects. We must ensure that we hold and process only the minimum set of information required for the purposes we have consent for. We must have explicit consent from each data subject for each form of processing of each piece of personal information.

What is Cyber Security? | IT Governance UK

Data subjects must be able to view and where appropriate correct, the information we hold about them and we must absolutely not perform any processing, which includes analysis, and even anonymised analysis, of data for which we do not have consent. Principle V requires us to establish the maximum time we need to hold personal data in a form which allows the identification of the data subject for each element of processing. This allows data controllers to keep raw data for long-term trend analysis, as long as the information is anonymous.

Principle VI reinforces existing data protection law and adds legal weight to good information security practice. It requires data controllers to ensure that personal information is adequately and appropriately protected from misuse, loss, destruction or damage. Where do you start? As with asking for directions in Ireland, the chances are you would not wish to be setting out from where you are currently.

But as every programme manager and consultant will gladly remind you, we are where we are so we best get on with it! It would also display what technical and managerial security measures protect each repository and what processing the systems and applications perform. You would have the ability to call up details of who has access to the applications and systems and whether the information can be accessed any other way.

Taking the example of a data controller with a medium to long range road-map, a few in-flight programmes and a several legacy systems, how would you approach this ideal? As a first step, and to prevent unnecessary pain later down the line, we recommend embedding the GDPR requirements into your road-map for future systems and applications.

Information & Cyber Security

Whichever is the case, data controllers need to be aware not only of the potential for fines, but also that all affected data subjects will be eligible for compensation, regardless of whether they have been materially damaged by the infringement. Yes, deep breath, you read that right…. Secondly, we recommend that you retrofit the requirements into your in flight programmes to the greatest extent possible.

For programmes in the early stages of analysis and design, full incorporation of the GDPR requirements should be a priority. Where significant work has already been done, they should be built into the road-map for future releases. Where they cannot be incorporated into the deliverables, additional management controls should be viewed as essential to avoid the accusation of negligence.


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This brings us to the legacy estate, which in all cases of new legislation, regulation or just new business requirements, is the biggest concern. The older a system or application is, the less easy it is to retrofit new requirements, especially those as broad and deep as the GDPR.

In many cases, additional organisational and access control measures may be sufficient to reduce the GDPR infringement risk until a legacy system is retired or replaced. In other cases, re-engineering may be required.

Managing IT Risk: Trends in Global Information Security

When reviewing your existing information security controls beyond the specific data protection and privacy measures discussed above, we recommend posing four questions:. Is all personal data adequately protected against risks liable to result in an infringement? If an infringement was to occur, would we know it had happened and could we identify the data subjects affected in a timely manner? Do we have a proven response capability to manage the impact of a data breach, including notifying affected data subjects and the supervisory authority?

Do we have a proven capability to recover from a breach so that the long-term viability of our organisation is not compromised?


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  6. One of the key features of the GDPR is the clarity it brings to data ownership — that being the data subject owns their data. As data controllers and data processors, we are the custodians of the information and are obliged to act accordingly. The terminology, a rarity for legislation, is clear and unambiguous, namely that the data subject has the right to:.

    What We Do

    The following activities should be carried out to determine what you have, why you have it, how you use it and whether you are compliant with the legislation. The scale of each activity will, of course, vary according to the scale and complexity of your organisation and business processes. In all cases, you should ensure that the scope includes personal and sensitive personal data relating to staff, suppliers and customers as each individual is a data subject with rights.

    Being transmitted internally or externally, including recipient and purpose and;.

    What is information security risk management?

    Assess GDPR compliance status of each identified instance of Personal and Sensitive Personal data being captured, stored, processed and transmitted and;. Information security management controls and processes against the GDPR principles. Identify opportunities for data rationalisation and process improvements.

    Information security is crucial to every aspect of your business — operational efficiency, profitability, business continuity, customer confidence, brand loyalty, protection against fraud and meeting regulatory requirements. Our penetration testing, pen testing, pen tests and cyber security testing has proven time and time again to be an effective security assessment of business IT infrastructure.

    This pillar aims to provide a more extensive catalogue of cybersecurity trainings in order to meet the diversity of the needs. It will also be able to use the resources of the 2 other pillars to improve and make the trainings even more concrete and realistic.

    3. Using security metrics

    It allows employees of a company to face a cyber-attack in an immersive and playful environment, and in real time. Home About. The Cybersecurity Competence Center C3 is the missing piece in helping Business to face the cyber risks, a priority since more than 15 years in Luxembourg. The first initiatives were born in the very beginning of the Century, thanks to the impetus of the Ministry of Economy. Threats and Vulnerabilities Observatory Be aware of the latest threats and vulnerabilities The first pillar aims to increase the collection of strategic data and information about ongoing threats to help businesses and organizations protect themselves.

    Watch the latest threats and vulnerabilities. Benefits Your defensive shield will become invincible stronger than ever. Testing Facility Test your cyber resilience This pillar consists of offering testing services for different categories of needs.