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Data Protection Impact Assessment and BIA
Answer:
If you identify your personal data as critical items for your business you could do this. But the DPIA should be kept a a separate process. -
Legacy backup data
Answer:
If you have huge amount of legacy backup data you should determine adequate retention periods. As a general rule unless there is a specific legal requirement or a legitimate interest personal data should be deleted after they are no longer needed for that specific processing activity. -
Employee data privacy
Answer:
If you only provide telecom services to companies this does not mean that you should only focus on your employee personal data. I am guessing that while providing the service to your corporate clients you would actually have access to some of their persona data as well. In this instance you would be acting as a data processor and your main focus would be to comply with the requirements of the Controller. You also have to have the Inventory of the processing activities that you perform on behalf of the controller as well. -
Difference between DPIA and data processing risk assessment
Answer:
If your risk assessment focuses only on the security of personal data then one of the main differences would be that DPIAs focus on the right and freedoms of personal data subjects. You could keep the personal data as safe as you want but this does not guarantee that the data is processed lawfully nor that the data subjects can effectively exercise their rights. -
Control gap treatment
Answer: If the gap refers to a standard's mandatory requirement, or to risks considered unacceptable in your risk assessment, it has to be solved at most before the certification audit. Otherwise, its deadline can be defined to a date after the certification, but you have to be prepared to present to the certification auditor the action plan related to the treatment of this gap and any evidence of results already achieved. -
Supplier Assessment questionnaire
Answer: There is no specific document for a Supplier Assessment questionnaire (such questionnaire is not mandatory to comply with ISO 27001 requirements), but you can drawn up one based on the Security Clauses for Suppliers and Partners document, since this document lists security requirements that can be put into contract with suppliers and outsourcing partners,and through them you can evaluate how prepared a potential supplier is. You also can take a look at the free demo of our Processor GDPR Compliance Questionnaire at this link: https://advisera.com/eugdpracademy/documentation/processor-gdpr-compliance-questionnaire/
This document can show you how a questionnaire to assess supplier’s compliance with should look like.
These articles will provide you further explanation about suppliers assessment:
- Which security clauses to use for supplier agreements? https://advisera.com/27001academy/blog/2017/06/19/which-security-clauses-to-use-for-supplier-agreements/
- How to make an Internal Audit checklist for ISO 27001 / ISO 22301 https://advisera.com/27001academy/knowledgebase/how-to-make-an-internal-audit-checklist-for-iso-27001-iso-22301/ -
DPIA template
Thank you for your answer Andrei. You have made some good points. Have a good day! -
DPIA and risk assessment
Answer:
The ISO27K risk assessment is aimed at identifying the risks for companies. However DPIAs focus on the risks to the rights and freedoms of data subject. Another difference is that DPIAs will be a legal requirement as of May next year as opposed to ISO standards that are from a legal perspective strictly voluntary. -
DPIA according to EU GDPR
Answer:
It relates to information security to the extend that the personal data is processed by certain IT systems thus those systems need to be secured in order to keep the integrity and availability of personal data. An existing ISMS system would , in DPIA , relate to the technical and organizational measures in place to protect the data.