GDPR – what is it? A new data protection framework which puts individuals back in control of their personal data
ICO 12 steps to GDPR compliance 7. Consent 1. Awareness 2. Document the personal data you hold 8. Children 3. Communicating privacy information 9. Data breaches 4. Individuals rights 10. Data protection by design and default 5. Subject access requests 11. Data Protection Officer 6. Lawful process for processing personal data 12. International Watch the video here… www.moneyinfo.com/Videos/GDPR12Steps
Step 1: Awareness Make sure key people in your organisation are aware that the law is changing. Get a team together involving compliance, HR and key decision makers and look at what needs to be done for May 2018.
Step 2: Document the personal data you hold • What information do you hold? • What is it’s purpose? • Where is it stored? • Where is it shared?
Information Asset Register Who is responsible for this information asset? Owner A way to identify the information asset. Name A description of what the information asset is and what It records. Specifically note if your Description information asset contains personal or sensitive information. e.g. SQL Database, Excel Spreadsheet Format Why do you hold this information and what it is used for. Purpose Where is the information stored? Location How is the information secured? E.g. password protected, encryption etc. Security Who has access to this information asset? Users How long is the data kept for and why? Retention Period What would be the impact of losing the information asset? Consider loss of confidentiality i.e. a Risks/Impacts data breach, loss of availability and loss of integrity. What would be the cost of replacing the information? Is this information shared externally with any third parties? External Sharing What is your basis for processing this information? e.g. consent, legitimate interest Legal basis
Step 3: Communicating privacy information “a concise, transparent, intelligible and easily accessible form, using clear and plain language…” ARTICLE 12
Step 4: Individuals’ rights • the right to be informed • the right of access • the right to be forgotten • the right to restrict processing • the right to data portability • the right to object • The right not to be subject to automated decision-making including profiling
Step 5: Subject access requests “Where possible, the controller should be able to provide remote access to a secure system which would provide the data subject with direct access to his or her personal data.” RECITAL 63
Step 6: Lawful basis for processing personal data • consent • necessary for the performance of a contract • compliance with a legal obligation • to protect the vital interest of a data subject • for tasks in the public interest • legitimate interests DETERMINE WHAT IT IS AND DOCUMENT IT
Step 7: Consent When capturing consent “…include: • the name of your organisation; • the name of any third party controllers who will rely on the consent; • why you want the data; • what you will do with it; and • that individuals can withdraw consent at any time.” INFORMATION COMMISSIONERS OFFICE
Step 8: Children Gain consent from someone with parental responsibility Apply consent rules when capturing and recording consent
Step 9: Data breaches • lost? • destroyed? • corrupted? • disclosed?
Step 9: Data breaches RECOGNISE INVESTIGATE NOTIFY MITIGATE
Step 10: Data Protection by Design and Data Protection Impact Assessments “In order to be able to demonstrate compliance with this regulation, the controller should adopt internal policies and implement measures which meet in particular the principles of data protection by design and data protection by default.” RECITAL 78
Step 10: Data Protection by Design and Data Protection Impact Assessments “… description of the envisaged processing operations… …assessment of the necessity… … assessment of the risks to the rights and freedoms of subjects… …measures envisaged to address the risks…” ARTICLE 35
Step 11: Data Protection Officer You need to appoint someone in your organisation, or an external adviser, who has the knowledge, support and authority to take responsibility for your data protection compliance.
Step 12: International Determine your lead supervisory authority .
The do’s and don’ts for keeping data safe
How can technology help? Data Access Data Quality Data Privacy by Design Secure communications Subject Access Requests . Data Portability
How can technology help? .
How can technology help? .
How can technology help? .
How can technology help? .
How can technology help? .
How can technology help? .
How can technology help? .
How can technology help? .
How can technology help? . @moneyinfotech www.moneyinfo.com
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