Certification as a Lead Implementer and Lead Auditor
With that background information, I have a question about certification as a Lead Implementer and Lead Auditor: is there an order in which one of these two certifications should be obtained before the other? I believe that in the immediate future Lead Implementer would be the more useful of the two for me, but is Lead Auditor certification a prerequisite for Lead Implementer?
Answer:
There is no mandatory order to pursuit Lead Implementer and Lead Auditor certifications (in fact you can go for one certification and not for the other, because there is no prerequisite relation between them), so you must consider your personal and business obj ectives to define the proper approach.
If you plan to implement an ISMS, then you should go for Lead Implementer certification, but if you plan to work as an auditor, then Lead Auditor would be probably better for you.
Visitors shouldn't be able to see who has signed in books before. This would mean that the personal data of the individuals signing in the books is disclosed to unintended recipients and the situation is considered a data breach.
2. What happens if somebody walks off with your visitors’ book? I’m afraid this is also a breach of data security and confidentiality.
Answer:
Walking off with the register will be considered a data breach.
3. If a visitor exercises their GDPR ‘Right to be forgotten’, verbally or in writing, you must erase/delete their personal information. How do you achieve this in your visitors’ book? Rip out a whole page?
Answer:
You could just redact the name of the visitor using a black marker or move to an electronic register.
4. How long does your visitors’ sign-in book sit in your reception?
Answer:
As mentioned before, the registry should not just sit in the reception to be consulted by everyone as that in itself is a data breach. The retention period in this case is something you need to establish by yourself depending on the types and categories of personal data you hold and the reasons for keeping the data. For example you could refer to the statute of limitations period in your local legislation.
5. How is it stored? What happens to the book when it’s full? If used visitors’ books are stored in a desk or cupboard, you’re in breach of GDPR because you’ve kept the information longer than necessary after the visitor has left, especially if they’re unlikely to return.
Answer:
When the register is full you just switch to a new one and archive the old one. Both registers, the one in use and the one which is archived should be kept secure and not made available to unauthorized persons.
6. Do you explain to each visitor how their information will be used, then gain the permission required under GDPR’s ‘Data consent and storage’ requirements before visitors sign your book?
7. Can you prove that each visitor has given their consent before they signed?
Answer:
You won't be relying on consent as a lawful ground for processing the data of the individuals borrowing or consulting your books. I strongly recommend that you use legitimate interest and in this case providing an adequate Privacy Notice will most likely suffice.
8. Do you need all the information that is stored in your visitors’ book? GDPR stipulates that you can only collect required information. Does the information you need about each person vary according to visitor type? How does your visitors’ book help you manage this? Or does it hold the same information about each person who visitsyour premises?
Answer:
I don't know what information you are asking from the visitors so I cannot provide you with an accurate answer. However, you need to consider the reason for asking the information. For example, if you only collect the information to be able to count how many people visited you, most likely name and surname will suffice.
If you collect the information to be able to identify with certainty who borrowed a specific book to be able to take legal action to recover the book you may need to collect more information.
All the purposes for which you collected personal data must be clearly explained in your Privacy Notice.
Without more details about the nonconformity, what I can suggest you is to check which objectives were defined for the ISMS (see clause 6.2) and how you can ensure if they are being achieved (see clause 9.1):
- Which monitoring methods were defined?
- When monitoring must be performed?
- Who must perform the monitoring?
- When the results of monitoring must be analyzed and evaluated?
- Who must analyze the results of monitoring and evaluation?
Record: Rules for the identification, collection and preservation of evidence
My question: What is the storage duration? The template doesn’t say anything about it.
Answer:
Retention time for evidences will depend mostly on laws and regulations your organization has to comply with, so you must consult those identified on the list of legal requirements to have a precise definition for this retention time, but a good start is to retain evidences for at leas three years (the period of a ISO 27001 certification)
I'm sorry about this confusion - the "Cloud Services Agreement Guideline" is not a document in the toolkit."
The term "Cloud Services Agreement Guidelines" refers to definitions (i.e., clauses) you can find in cloud services agreements you have signed with your hosting providers, applicable to a control (e.g., a clause defining how backup must be executed or where backup copies must be stored), so it can refer to one or more documents.
>1. What is the difference between Privacy Notice and Personal Data Protection Policy?
Answer:
The GDPR increases the amount of information you need to include in your privacy notices. The information is provided to the data subject through Privacy Notices. Notices must also be concise and intelligible and provide the information required under art. 13 and 14 of the GDPR. On the other hand, the Data Protection Policy as stated previously is a statement of the company to process data in accordance with the GDPR and its principles. So both the purposes and the audience is different.
>2. What is the difference between Employee Privacy Notice and Employee Data Protection Policy?
Answer:
Keeping in mind the description and purpose of a Privacy Notice note that the Employee Privacy Notice is tailored as to be used for informing the employees what the company usually uses their personal data for. The Employee Data Protection Policy is a document which is setting up the rules for processing personal data by the HR department.
Reporting a gap analysis
Answer
First, I would not use the word negative. You are starting to implement a quality management system (QMS), you need allies and people can become very upset when someone comes saying that they are wrong.
I would start by remembering all the reasons the organization wants or needs an ISO 9001 QMS. Then I would arrange ISO 9001 clauses (gap analysis questions and answers) in groups that anyone can relate to. People don’t know clause 8.4, but they know what purchasing or income inspection are. For example, you can group topics around commercial activities, around warehouse activities, around purchasing activities, ...
For each group I would present the gap analysis question, the answer and the why for the topic. Then, I would present a summary of the ISO 9001 requirement stressing that ISO 9001 does not give an answer about how to close the gap. For each group I would present a proposal about a team composition and timing for developing the way to close the gap. If y ou use our Free ISO 9001:2015 Gap Analysis Tool you can use the number at the bottom to monitor the progress impartially.
An organization with a quality management system should have a quality policy. A quality policy is a set of intentions and direction for an organization as determined by top management. You will not see this in ISO 9001:2015, this is my practice. When I work with an organization’s top management in developing their quality policy I recommend thinking about some questions:
Who are our target customers and other very relevant interested parties?
What are the most important requirements for those target customers and other very relevant interested parties?
In what activities should our organization be excellent to be able to satisfy target customers and other very relevant interested parties?
After discussing the questions and answers and after arriving at some consensus, I invite the organization to write a text with the following structure:
To whom do we work (We work for clients that value …)
What are our top priorities. In what things we need to be exc ellent.
Add the commitments included and required by ISO 9001
That way you will write a guiding document that will focus your organization in a strategic way and translating that policy into objectives will be easier.
Answer
Your organization is not an abstract entity living in a perfect world. For example, top management should not make decisions without considering what is happening now, or what can happen in the future of the economic, social, political or technological environment around the organization. Imagine an organization deciding to invest heavily in a technology that can become obsolete or deciding to open an office at another country that will impose greater import restrictions.
Organizations are not really free to decide what to do, they should take into consideration their past, their experience, their DNA, their strengths and their weaknesses. The set of internal and external issues that affect an organization is what ISO 9001 calls the context.
This website stores cookies on your computer. These cookies are used to collect information about how you interact with our website and allow us to remember you. We use this information in order to improve and customize your browsing experience and for analytics and metrics about our visitors both on this website and other media. To find out more about the cookies we use, see our Privacy Policy.
If you decline, your information won't be tracked when you visit this website. A single cookie will be used in your browser to remember your preference not to be tracked.