Answer:
Yes, you still need to do an internal audit. Internal audits and gap analysis are different things and have different purposes. A gap analysis identifies what is missing when it is supposed that something is missing. An internal audit is performed on a process that is supposed to be already operating according to the audit criteria.
The following material will provide you information about gap analysis versus internal audit:
Normally, each auditor uses his own checklist. So, you can be audited by someone more focused on formalities. ISO 9001:2015 has no mandatory procedures. So, auditors may focus their attention more on results, on effectiveness and less is procedures.
The following material will provide you information about external audits:
The impact measurement is based on a 4-point scale starting with 1-marginal up to 4-catastrophic.
Could you please provide a description or definition variance between 1 – Marginal and 2 – Acceptable?
Answer: Marginal is an impact barely perceived and that does not affect business continuity.
Acceptable is any impact that is perceived by the organization, users or customers, but does not require the organization to implement controls to ensure the service levels agreed with customers.
We are doing third-party inspections of vessels and in our report format we are taking pictures of the seaman’s certificates and include those in the report we are making.
The certificates contain personal information such as; Name, DOB, certificate number and picture of seaman. We are issuing the final report to the client normally the vessel owner or the vessel owner client e.g. oil company.
We are storing the information in our data base and use the information to verify the skills of the seaman.
My question to you is do we need to implement all the controls identified in the statement of applicability that I have identified under EU DGPR see column “Justification for selection” in the attachment or is it sufficient to implement the controls that we have identified in Appendix 1 Risk Treatment Table?
Answer: To be complaint wi th ISO 27001, controls from Annex A must be implemented if at least one of the following occurs:
- There are unacceptable risks that justify the application of the control
- There are legal requirements (e.g., laws or contract clauses) to which the organization must to comply with
- There is a Top Management decision to implement the controls, by considering then as good practices.
Considering that, you must implement controls not only to treat unacceptable risks identified in the risk assessment, but also controls that can fulfill requirements of the EU GDPR.
The 10 days period is just a suggestion which we considered to be reasonable considering that you roughly have 30 days to provide an answer to the data subject.
Name of the registration related to IT / System / Software / paper document (means the software used in the PC of each our Employee)? Is there a precompiled guide regarding this attachment?
Answers:
1. Both sheets need to be filled in as most likely it you are a company established in the EU you will be having processing activities for which you are acting as controller such as HR related activities (recruitments, onboarding, HR administration) as well as activities where you are acting as a processors for instance if you are a company providing IT maintenance for a another company (controller) and while doing that you are having access to the controller's personal data.
2. That particular column should filled in with either the System that is processing the personal data for a specific processing activity or the processing activity itself (see the examples regarding HR) this is because there may be several processing activities that do not rely on an I system (e.g. resisting the visitors, or training attendance lists).
There are several notices that can be included in there such as: website privacy notice, employee privacy notice, recruitment privacy notice, visitors privacy notice, etc.