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  • Privacy Notice Webinar - EU GDPR Premium Kit questions

    1. Tudor Galos mentioned using a four column table in a privacy notice. I didn’t get the column details quickly enough. Were they “category of data subject”, “personal data to be processed”, “purpose”, “legal basis”?

    This was a recommendation on customizing the Privacy Notice template in your Privacy Notices template. The columns I recommended for the association between personal data categories & purposes were “Personal Data Categories”, “Purpose of processing”, “Legal Basis”.

    2. TG also referred to the kit containing granular privacy notice. Did he just mean that you provide different ones for e.g. employees, supplier employees, web users etc?

    Yes, I was referring to the privacy notices you have in EU GDPR Premium Documentation Toolkit. In general, if you have a specific processing operation, different than the ones you had until now, you might choose to write a new privacy notice to inform the affected data subjects.

    3. Our privacy notice should give the supervisory authority a data subject can complain to. We are based in the UK so obviously we give the ICO for UK residents. We process the personal data of EU residents, mainly from Germany, France and Spain. We have appointed an EU Representative with an address in Germany as that is where the majority of the data subjects are. Which EU supervisory authority should be put in the privacy notice?

    For people in the EU you could provide the details of the EU Representative and of the relevant data protection authority in Germany, from the region your EU Representative is established.

    4. When dealing with a corporate client or supplier, we may well be given the personal data – usually contact details – of other staff members. How do deal with notifying them that we have their details. Commercially, it would be a bit odd if every time we emailed them direct. I could see us upsetting clients!
    If you are dealing with a corporate client or supplier, for the business relationship interactions – invoicing, emails with key updates, support, etc – you are both data controllers. If your client/supplier is giving you details of other staff members, they are responsible for the processing and they should make sure that they inform their staff about this processing (transfer of information to you).

    Please also consult these resources:

  • Do we need ISO 13485?

    According to the MDR 2017/745, Annex VIII Classification rules, Rule 16 covers the disinfectant and states the following: 
    All devices intended specifically to be used for disinfecting or sterilizing medical devices are classified as class IIa, unless they are disinfecting solutions or washer-disinfectors intended specifically to be used for disinfecting invasive devices, as the end point of processing, in which case they are classified as class IIb.
     
    So, if your cleaning chemicals are used to disinfect those devices (mentioned in rule 16), they are either class IIa or class IIb. This means that you need to have certified your cleaning chemicals according to the MDR and your quality management system according to the ISO 13485:2016. 

  • Career in GRC domain.

    Governance, Risk, and Compliance is not our field of work, but considering information security aspects related to GRC you should consider these certifications:

  • ISO 27001 Lead Implementer – this certification recognizes people who have competency in the ISO 27001 implementation process.
  • ISO 27001 Lead Auditor – this certification recognizes people who have competency in auditing an ISM S against ISO 27001 requirements and want to become certification auditors (and this provides more confidence to an organization for being certified).

    • These articles will provide you with a further explanation of ISO 27001 personnel certifications:

    For courses related to these certifications, please see:

  • ISO 27001 Management Review : Fulfillment of the security objectives

    Thanks a lot for your recommendation. Fortunately i've got the advisera toolkit so will be able to see what is in the template shared :).

  • Doubts about the package of documents to buy

    To comply with the point you listed you can use the ISO 27001 documentation toolkit (https://advisera.com/27001academy/es/paquete-de-documentos-sobre-iso-27001/). Some documents in this toolkit that can help fulfill some of your points are:
    - Information Classification Policy (point 1 )
    - Security Procedures for IT Department (points 2, 3, 4, 5, and 6 )
    - IT Security Policy (points 2, 3, 6, and 9)
    - Access Control Policy (points 5 and 8)
    - Incident Management Policy (point 7 )
    - Statement of Acceptance of ISMS Documents (points 10 and 11)
    - Confidentiality Statement (points 10 and 11 )

  • Query on ISMS Scope

    You only need to include the implementation project team (i.e., yourself and the internal audit team) in the ISMS scope in case once the implementation is finished the project team will remain to perform other activities related to the ISMS.

    In your case, for example, since you are part of the IT Department, your role does not need to be explicitly included in the ISMS scope since the IT Department is in the ISMS scope. As for the Internal Audit Team, in case they will not perform the internal audit over the implemented ISMS, it does not need to be included in the ISMS scope.

    Regarding the offices, you only need to include them in the scope in case you consider that the information in the offices that are outside the scope of the outsourced services needs to be protected (e.g., printed information stored in the offices). 

    In case only information that is handed by the outsourced services is to be protected, then the offices do not need to be included in the scope.  

  • ISO 45001 and ISO 14001 in welding and fabrication shops

    Both ISO 45001 (Health & Safety management) and ISO 14001 (environmental management) allow your organization to go beyond simply meeting laws for the environment or health & safety, and instead have a coherent system that allows you to proactively manage these parts of your business. This is true for a welding and fabrication shop, just as it is for any other organization. The standards help to focus your efforts on identifying environmental interactions (called environmental aspects) and OH&S hazards with a focus on identifying the risk that is posed by each in order to apply controls to prevent environmental damage, injury or ill health.

    You can read a bit more on the benefits of ISO 14001 and ISO 45001 in the articles:

    • 6 Key Benefits of ISO 14001 https://advisera.com/14001academy/knowledgebase/6-key-benefits-of-iso-14001/
    • 4 key benefits of ISO 45001 for your business https://advisera.com/45001academy/blog/2015/09/30/4-key-benefits-of-iso-45001-for-your-business/

    • Performance Evaluation

      As an international standard, ISO 45001 is written to be used by any organization in any industry. As such, it will tell you what needs to be done in a process for OH&S, but not how to do it. So, ISO 45001 does not give details on how to conduct monitoring and evaluation, only providing requirements that you must determine what to monitor and evaluate and that you must ensure evaluation is adequate. As conducting monitoring and evaluation is something that will be specific to each organization, I cannot give you a specific procedure for M&E, nor what criteria to evaluate against as this will differ from industry to industry, as well as area of the world. The best I can recommend is to look at industry best practices that are in place where you are located and work with these to develop the M&E process that will be best for you. Remember, the reason that ISO includes monitoring, measurement, analysis, and performance evaluation into the standard is to collect data that can be used to make good evidence-based decisions. So, choosing the right data and the right evaluation method is critical for this to be effective. 

      You can read a bit more on how monitoring and measurement work in the article:

      • How monitoring, measuring, evaluation, and analysis in DIS/ISO 45001 works https://advisera.com/45001academy/blog/2016/03/09/how-monitoring-measuring-evaluation-and-analysis-in-disiso-45001-works/ 

      • Questions related to ISO 27001 Controls

        Please note that the controls you mentioned, as well as all controls from ISO 27001 Annex A, are applicable only in the following cases:

        • There are relevant risks that demand the implementation of controls
        • There are legal requirements (e.g., laws, regulations, or contracts) that demand the implementation of controls
        • There is a management decision to implement controls (e.g., by considering them a good practice)

        Considering that, according to ISO 27001, if none of the above conditions occurs, you do not need to implement a control.

        Regarding selection control criteria, a control must be selected considering its capability to reduce the likelihood and/or impact of a risk so the risk value decreases to an acceptable level.

        Regarding “mandatory controls” there is no such thing prescribed by the standard. During the audit, the certification auditor will look to see if the stated applicable controls make sense considering the results of the risk assessment and applicable legal requirements.  

         

        These articles will provide you with further explanation about risk management:

        This material will also help you regarding risk management:

      • Different companies in scope ISO 27001

        1 - I have some questions regarding ISO 27001- ISMS scope and organizational units. We are implementing the documentation in two of our companies (same corporate group). The whole Company X is within the scope but only the compliance office in Company Y. We include them both in the scope. Is this correct or do we have two sets of documentation? We are using the same equipment and facility at the moment.

        If I understood correctly, you have two legally separated companies using the same equipment and facility at this moment.

        Considering that, first you need to align with your certification body the possibility to have a single scope for two legally separated companies.

        In case this is acceptable by the certification body, you can have a single set of documents, but please note that when you start using different equipment and facility you will need to review the documents.

        2 - I also have a question regarding Risk assessment table. To be compliant with the ISO standard- should we change the risks in the risk assessment after the risk treatment? For example, if risk X has been reduced due to implementation of a policy, should we change the risk from e.g., 3 to 2 in the risk assessment? Or should we not change the risks after treatment at all?

         Risks identified during risk assessment must not be changed after risk treatment. What happens is that, after risk treatment, you need to assess the residual risk, i.e., the risk value after the applied treatment.


        This article will provide you with further explanation about residual risks:
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