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I would like to have known whether it is possible that jointly responsible persons can assert a legitimate interest as a legal basis?
Legitimate interest is more deeply explained in the preamble of GDPR. Paragraph 47 of GDPR explains how to use legitimate interest as a legal ground.
The key element of legitimate interest as a legal ground of data processing is the existence of a relevant and appropriate relationship between “the data subject and the controller in situations such as where the data subject is a client or in the service of the controller.” (see paragraph 47 of the Preamble of GDPR)
Therefore, you must assess whether the four companies have a relevant and appropriate relationship with the customer (i.e. they all provide a service to the customer like sales of goods and logistics).
It must be assessed whether “a data subject can reasonably expect at the time and in the context of the collection of the personal data that processing for that purpose may take place.” It means that the customer who disclosed his personal data for a certain purpose can reasonably expect that his data will be processed by all the four companies because of the nature of the service provided.
In those cases only legitimate interest can be used as a legal ground of data processing by co-controllers.
Example: 4 independent organizations/companies want to share their customer and supplier data because they partially overlap. If one of the four companies wants to create a new customer, they should first be able to search in a joint program to determine whether it already exists so that they do not have to create it again. Each of these four companies can view this customer record and change it if necessary.
Can I assert a legitimate interest here and say that it makes work easier for the four companies and also means data minimization?
Paragraph 48 in preamble rules the situation of group companies or grouped undertakers which jointly process personal data.
According to paragraph 48 of the GDPR Preamble, the controllers “may have a legitimate interest in transmitting personal data within the group of undertakings for internal administrative purposes, including the processing of clients' or employees' personal data.”
Based on your information, as an auditor, I would write that the ISO 9001:2015 clause is 7.5.3 b). Let us consider that you are writing an audit nonconformity. Now, the manager of the warehouse/delivery, when answering the request for corrective action, should look for the root cause of the contradiction. For example, during his/her investigation he/she might discover that it is a lack of competence issue (clause 7.2), or a misleading identification issue (clause 8.5.2), or a lack of people at a certain shift (clause 7.1.2).
The following material will provide you information about audit nonconformities:
- Article – How to write a good ISO 9001 audit nonconformity? - https://advisera.com/9001academy/blog/2018/04/24/how-to-write-a-good-iso-9001-audit-nonconformity/
- Article - Seven Steps for Corrective and Preventive Actions to support Continual Improvement - https://advisera.com/9001academy/blog/2013/10/27/seven-steps-corrective-preventive-actions-support-continual-improvement/
- Article - How to use root cause analysis to support corrective actions in your QMS - https://advisera.com/9001academy/blog/2016/03/01/how-to-use-root-cause-analysis-to-support-corrective-actions-in-your-qms/
- ISO 9001:2015 Internal Auditor Course - https://advisera.com/training/iso-9001-internal-auditor-course/
- Book - ISO Internal Audit: A Plain English Guide - https://advisera.com/books/iso-internal-audit-plain-english-guide/
#1 If this list includes items you need to manage in order to deliver a service(s) - then you need to document them.
#2 Partially SDP can be seen as a functional specification (with extended content). But, that also depends on what kind of services you are delivering, how deteiled your functional specification is, etc.
Here is the article with more details: ITIL Service Design Package – everything under one roof https://advisera.com/20000academy/blog/2014/10/07/itil-service-design-package-everything-under-one-roof/
Capacity Management - well, part of the Capacity Plan relates to business requirements. But you have to, also, plan how to answer (with technology) those requirements. And you have to define how to monitor usage of these resources, react when you need, etc.
This article can help you further: ITIL Capacity Plan – A document you need, but probably don’t have https://advisera.com/20000academy/knowledgebase/itil-capacity-plan-a-document-you-need-but-probably-dont-have/
There's is no real difference between AS9100 and EN9100. These are just the different publishing titles for North America and Europe, however, the requirements are thre same.
No. The current version of ISO 9001 is the one published in September 2015 and there is no revision since then.
In this article you can check the history of ISO 9001 revisions - The history and future of the ISO 9000 series of standards - https://advisera.com/9001academy/blog/2019/04/15/history-of-the-iso-9000-series-of-standards-and-what-to-expect-next/
Truth is that ISO 9001 and ISO 17025 have different purposes. ISO 9001 is about implementing a quality management system and is applicable to any kind of organization. Quality management systems can be certified by a certification body.
ISO 17025 is about “General laboratory competency of testing calibration requirements” and is applicable to laboratories that produce results, like composition of a sample, that can be used in a court of law. ISO 17025 main concern is competent, impartial, and consistent operation of laboratories. ISO 17025 is mainly used by calibration laboratories. Laboratories are accredited by an accreditation body.
The following material will provide you more information about ISO 17025:
- ISO 17025 vs. ISO 9001 – Main differences and similarities - https://advisera.com/17025academy/blog/2019/07/11/iso-17025-vs-iso-9001-main-differences-and-similarities//
- Six key benefits of ISO 17025 implementation - https://advisera.com/17025academy/blog/2019/10/18/six-key-benefits-of-iso-17025-implementation/
- Diagram of ISO 17025 Implementation Process - https://info.advisera.com/17025academy/free-download/diagram-of-iso-17025-implementation-process
- What is ISO 17025? - https://advisera.com/17025academy/what-is-iso-17025/
- Please check our ISO/IEC 17025 Blog - https://advisera.com/17025academy/blog/
- Download free ISO/IEC 17025 materials - https://advisera.com/17025academy/free-downloads/
Whenever ISO 9001:2015 uses the formula “maintain documented information” it is about keeping documents approved, distributed and updated. Whenever ISO 9001:2015 uses the formula “retain documented information” it is about keeping records. This article List of mandatory documents required by ISO 9001:2015 - https://advisera.com/9001academy/knowledgebase/list-of-mandatory-documents-required-by-iso-90012015/ gives an idea about documents and records relevant for an ISO 9001:2015 quality management system.
Advisera developed an ISO 9001:2015 Documentation Toolkit - https://advisera.com/9001academy/iso-9001-documentation-toolkit/ with live expert support. A tool to accelerate the design of quality system documentation. Please check also this free webinar on demand - How to use a Documentation Toolkit for the implementation of ISO 9001 - https://advisera.com/9001academy/webinar/how-to-use-a-documentation-toolkit-for-the-implementation-of-iso-9001-free-webinar-on-demand/
You can enroll for free in this course - Free online training ISO 9001:2015 Foundations Course - https://advisera.com/training/iso-9001-foundations-course/
- Book – (where I use the process approach this way) - Discover ISO 9001:2015 Through Practical Examples - https://advisera.com/books/discover-iso-9001-2015-through-practical-examples/
Please check this article - List of mandatory documents required by ISO 14001:2015 - https://advisera.com/14001academy/blog/2019/08/27/key-iso-14001-benefits-to-customers/nowledgebase/list-of-mandatory-documents-required-by-iso-140012015/ There you can see that a procedure for identification and evaluation of environmental aspects and impacts is not mandatory. What is mandatory is having one or more documents stating:
The following material will provide you more information about aspects and impacts:
- Article - 4 steps in identification and evaluation of environmental aspects - https://advisera.com/14001academy/knowledgebase/4-steps-in-identification-and-evaluation-of-environmental-aspects/
- Environmental aspect identification and classification - https://advisera.com/14001academy/blog/2019/08/27/key-iso-14001-benefits-to-customers/nowledgebase/environmental-aspect-identification-and-classification/
- Free webinar - Free webinar - ISO 14001: Identification and evaluation of environmental aspects - https://advisera.com/14001academy/webinar/iso-14001-identification-and-evaluation-of-environmental-aspects-free-webinar-on-demand/
- Enroll for free in this course – ISO 14001:2015 Foundations Course - https://advisera.com/training/iso-14001-internal-auditor-course/
- Book – The ISO 14001:2015 Companion - https://advisera.com/books/the-iso-14001-2015-companion/
Here are the answers:
Document Owner, Document Approver, and Document Reviewer: are they normally the same person?
They could be the same person in a very small company, but in large companies you should try to have different persons for these roles. Even for a very small company you should try to have a different person for a reviewer, in order to create better documents.
When should the name be noted and when the role/dept. ?
When you describe roles and responsibilities, you should write job titles - this way when a person leaves the company or changes the position you do not need to change the policy. You can use person's name in the Change history of the document to have a record who exactly has made which changes; you can also use person's name when you make a record of who has approved the document.
Should Owner, Approver, Reviewer… all be on de Document? Or only author and owner?
ISO 27001 does not prescribe such things - best practice is to have author and approver of the document.
See also:
These materials will also help you regarding document management:
- Book Secure & Simple: A Small-Business Guide to Implementing ISO 27001 On Your
Own https://advisera.com/books/secure-and-simple-a-small-business-guide-to-implementing-iso-27001-on-your-own/
- Free online training ISO 27001 Foundations Course
https://advisera.com/training/iso-27001-foundations-course/