Step 1 – Conduct a Privacy Impact Assessment (PIA)
Why?
Enables you to identify all the processes/activities that involve personal data and demonstrates to the ICO that you have carefully considered personal data within your business.
How?
Complete a PIA for each information stream in your business, we have a host of template documents to help you and your business comply, contact us for further information.
Step 2 – Data Protection Policy Statement
Why?
This policy is your commitment/statement of intent as an organization to Data protection
How?
If you don’t have a DPS you will need one, then you need to consider if it needs to be publicly available or internal only. You should send it to new and prospective clients and share with suppliers.
Step 3 – Data Retention Policy & Data Retention Schedule
Purpose:
Data Retention Policy – This is required to support the creation, retrieval, proper storage and preservation of essential personal data records, and to enable identification and destruction of information where there is no continuing business, legal or historical significance.
Schedule – This schedule defines the different types of records typically found in businesses. It may not capture all the personal data/records that you may have in your company. Where any are missing, you need to add these to the ‘Other’ tab within the document. The schedule defines any legal retention requirements/ guidance on best practice from the ICO.
Action: Make the Policy and schedule available to staff.
Step 4 – Privacy Policy Template
Why?
In the interest of transparency (a GDPR principle requirement), you are required to provide privacy information to data subjects when you are collecting their personal data. Typically you will find a Privacy policy is put onto the website (as generally this is where you may have data capture forms).
How?
Have a look at what you have got already in your Privacy Policy and if it needs updating within the section related to Legal Basis for processing (as per the PIA/Data Matrix outputs) as not all may apply.
Step 5 – Security Incident Procedure
Why?
This is the document that you need to describe the process for reporting data breaches or security weaknesses, events, and investigation of security incidents. All staff must be made aware of document and understand the procedure as they have responsibilities to be able to know how to report breaches/ security incidents as they become aware of them.
How?
Step 6 – Information Security Breach Checklist
Why?
The checklist is to capture the key elements relating to a data breach to ensure actions are recorded and progressed as appropriate. The root cause can then be understood, and that is any new/changed controls are needed to be made and applied as part of the lessons learnt activities.
How?
Step 7 – Subject Access Request (SAR) Procedure
Why?
As stipulated by GDPR any individual that you hold information on has a right to know what data you hold on them eg name, address, etc – this info can be requested by an individual using a ‘Data Subject Access Request’.
How?
Write up your procedure outlining the steps to be followed by staff upon receiving this request, what information they need to record and how to go about it. This will ensure that your company receives and processes Data Subject Access Requests in accordance with the General Data Protection Regulations.
Step 8 – Subject Access Request (SAR) Log
Why?
There are rules relating to how long you have to respond (within 30 days) to these requests and this log enables you to keep track of any requests in progress, or any historical requests made. This log is linked to/ referenced within the Subject Access Request procedure.
Step 9 – GDPR Staff Training
Why?
Most data breaches/ Information Security breaches/incidents can be traced back to an individual’s actions or decisions. Providing awareness training to staff is a form of control that you may need to evidence to the ICO/Client in the event of a data breach.
How?
Step 10 – Supplier Data Compliance Questionnaire
Purpose:
This questionnaire is to check that the suppliers that your business shares personal data with are GDPR compliant. It is a requirement for your company to check the security and data protection compliance of any processors/ sub-processors used by the business
How?
Next steps………
