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In this last and final blog, we will explore Data Breeches and Privacy Impact Assessments, including documented processes for protecting personal data, information security and cryptography policy, procedures, etc.
Click here to read Part 1 and Part 2.
GDPR takes a dim view of data breaches. Organisations need to have procedures in place, to proactively detect and report any suspected or actual data breaches. All data breaches of personal data then need to be recorded and investigated. Issues must be addressed and security improved, documenting improvements.
Regular use of penetration (or ‘PEN’) testing, can allow experts to continuously monitor how secure systems are, with recommendations for resolution, to be followed up. Annual or at more frequent cycles are becoming popular, particular where software and solutions are cloud hosted. These offer new issues, than the well known on-premise options. That does not necessarily make cloud hosted solutions any less secure potentially, often quite the reverse, but it is prudent to check and be sure they are.
Data Protection must be designed into all of our solutions, that are processing personal data, by design. The ICO has what are called ‘Data Protection Impact Assessments’. This is a code of practice and readers will find more details on this link - https://www.google.co.uk/search?client=firefox-b&dcr=0&q=Opinion22017ondataprocessingatwork-wp249.pdf . These cover core processes at work, such as recruitment, monitoring of ICT usage, time and attendance, video and vehicle monitoring, among others. Reading more it is easy to see how our processes may carry data protection risks.
Does your organisation need, or have a designated data protection officer? If not, you may now need to consider one. Most socialhousing organisations I work with, have designated person(s).
Finally, the last key area is if your organisation processes data beyond a single EU state. This will certainly affect landlords operating within the UK and the Republic of Ireland (Eire). I have worked with more than one RSL in Ireland, that had schemes operated in the north and south. This is considered ‘Cross Border Processing’. A lead data protection supervisory authority, needs to be determined. This most likely would be where a central Housing Management System was based or operated from. Of course, some RSL’s may well operate on two separate systems.
So, from what I have tried to put together above, hopefully will give you the confidence that GDPR is not something to be afraid of. You are perhaps already well on the way to compliance already. Tackle the gaps before next Spring (2018) and you will be on your way!
Related Post: Don't be a demo room dummy!
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(c) Tony Smith, Acutance Consulting www.acutanceconsulting.co.uk 07854-655009
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