Even though GDPR is right around the corner, it makes a lot of sense - practically and financially - to maintain your traditional information security measures, because compliance with the Data Protection Regulation both can and should build upon your existing security measures.
Picture this: it’s the end of May and you’ve managed to fulfil the criteria of the EU Data Protection Regulation - you’ve achieved GDPR compliance. But how do you make sure you stay compliant in the future?
No doubt the GDPR implementation project was big and required a team effort. There might even have been extra resources allocated, as everyone realised the importance of getting this right. But now that the deadline has passed, and the goal has been met, your co-workers need to get back to their day-to-day assignments. So how do you successfully maintain continuous GDPR compliance with half the people, and maybe even half the resources?
In less than a year, the EU Data Protection Regulation comes into force. That’s ample time – if you manage it wisely, that is. Here are three useful tips that will help you prioritise your tasks and effectively make sure your organisation is prepared come 25th of May, 2018.
The EU data protection regulation is about getting those who process personal data used to the right processes. However, when it comes to compliance, the GDPR is very much about getting used to doing what is necessary. No more, no less.
At Neupart we have identified three areas in which you can save time, money, and worrying:
Climbing that mountain of compliance, over and over again.
The GDPR has been with us for a year, and everyone is (still) panicking. Becoming compliant and staying compliant are two very different things. In this blogpost, I will highlight the difference between the two and how to tackle the challenges that may arise along the way.
For the better part of a year, we have all been told that the EU GDPR is here, and that we will need to live up to a host of new requirements. The fear mongers have also told us about the huge fines we will be subject to, and just how far away from being compliant we all are.
So, there has been a lot of talk about what the requirements we will be hit with are, but there has not been as much talk about how to actually run an implementation project. And a lot of that talk is based on interpretations of the regulation and - in many cases - an unfounded over-implementation of the regulation.
Data Protection Officers. It’s a topic that seems to be on everyone’s mind now that we actively start to prepare for the implementation of the GDPR, but who really needs them?
Anyone working with information security management is by this stage well aware of the upcoming EU General Data Protection Regulation. Come to think of it, even those not working with information security management have probably heard of it too, considering the amount of coverage it has gotten. It’s no wonder, really, given that the new regulation will be the biggest data protection regulation to date. Even though it is being set by the European Union, it will affect companies worldwide. This is because together, the 28 EU member states not only represent the world’s largest economy, but are the top trading partner for 80 countries. Effectively, this means that any country dealing with personal data from citizens of the European Union will need to comply with the GDPR.
Soon after the news about the GDPR broke, another abbreviation started popping up everywhere: DPO. Of course, a Data Protection Officer is not a new role per se, but with sudden focus on the legality of data protection, it only makes sense that we start focusing more on the their role. In fact, the International Association of Privacy Professionals originally estimated that the new data protection regulation would require 28,000 DPOs in Europe and the United States. They have now increased that number up to 75,000 new DPO positions, worldwide. 75,000 is a lot of positions to fill, which leads to the question: who needs a Data Protection Officer?
You should be involved in security since security means something to your customers and because cyber attacks and security incidents are beginning to occur within all kinds of businesses. We have all seen the numerous examples of data breaches, attacks and other security incidents in the news. Often, one might expect or hope the involved organisations were better protected then they actually were. Information security is very much on the agenda, both in the business world and in the media.
Your customers, regardless of whether you sell directly to customers or to other businesses, are presently interested in the topic. That is why you as a manager and a senior executive should take an interest in whether your organisation is sufficiently prepared for a major cyber attack or a systems crash. That should be as good an argument as any! However, there are even more good reasons that I would like to share with you.
Brand image and profitability: Perhaps you have spent years slowly but surely building credibility for your brand name(s). You want your customer to have confidence in you. One security incident can quickly serve to reduce the trust and confidence you have gained to such a degree that even the best (or most expensive) image campaign will not be able to bring it back.
Fees: Add to this the enormous costs to you when you need to deal with a major security breach. Such costs are incurred both due to the incident itself and the following investigation, cleanup and restoration. Theft of company secrets and/or intellectual property rights, as well as industrial espionage can obviously be expensive and even a threat to the very existence of some companies. Afterward, it will surely be shown that more investment in preventive security measures would have made good sense and would have saved money. Moreover, since the threat will continue to develop, it would be a good investment for the future as well.
Legal Statutes: You are subject to certain legal requirements demanding that you have a sufficient level of information security. Bear in mind present and future Personal Data Acts. The future EU personal data legislation (an ordinance) is expected to passed so that it will apply in all EU Member States. It provides for companies to pay fines of perhaps as much as 5% of their turnover for computer security breaches. There is a comprehensive requirement that the parties be notified (data breach notification), which is both expensive and difficult to perform. Add to this a number of industry-specific requirements: for example, that financial enterprises must comply with financial supervisory authorities' requirements concerning information security, requirements placed on the energy sector, the health sector and for state-run enterprises to comply with the ISO 27001 standard.
Governance Requirements: Corporate governance requirements determine 1) that management set out the procedures necessary for risk management and internal inspections, 2) that the administration take a position on strategic and commercial risks and 3) that managers who negligently has caused the company to suffer damages shall pay compensation for such damages. In other words, there is also an array of legislative reasons to be interested in information security.
Review: You likely also strive for your review to be consistent with most of everything that might be found in those long review guidelines. Your information security will also be reviewed. Keep in mind as well, that regardless of the fact that accounting firms play a dubious double role (at the same time offering a wide range of both executive and advisory consultancy services within the field of information security), it pays for you to prepare for the review proactively. It should be easy for you to document that you are in control of your information security.
However, what should you as an executive do, in addition to taking an interest in the topic? Easy: You should A) communicate to your organisation that security is important, that it is a basic condition for your business activities and b) you should investigate whether you have allocated sufficient financial and human capital in your organisation to deal with the everyday, practical management of your information security.
If you want to get a little bit deeper into the subject, I recommend you examine your maturity level in these areas:
Policies, rules, procedures and documentation
Risk management (risk assessment and continual risk treatment)
Incident management and contingency plans
Proper governance and management of information security has become a common best practice simply because it has become a necessary condition for most commercial activities. That is why a manager should be interested in information security.
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