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Data Privacy
Data Privacy
Every organization with personal data is bound by various Data Privacy laws. In order to comply an an organization must have defined data privacy policies, data controls, and data mapping. This provide organizations with an objective analysis of their data privacy posture to understand their shortcomings and address them with a prioritized remediation plan. More and more states and countries have data privacy rules and you do not need to do business in those states or countries, just have data on residents of those regions.
What to do?
Get a handle on the data (Who, What , Where, When and How)
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Types of Data Processed/Stored
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Data Classification
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Regions (Subjects and Storage)
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Methods of processing/storage
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Third Parties Involved?
Basis of Processing
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Why does data processing occur?
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What does the privacy policy/notice say?
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What do contracts (if any) say?
General Security Review
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Vendor Management
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Asset Inventories
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Incident response
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Revamp of Privacy Policy Updates must be done annually due to changing legislation
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Privacy Program Documentation
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Contract/Agreement Review/Revision
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Opt-out options (CCPA)
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Data Breach Requirements must be embedded into an Incident Response
Where to start? Get an Assessment
Perform an audit on the environment that will identify and document the baseline state of information security within the organization. The audit will identify areas (both in technology and process) where the baseline state is deficient.
A Full information data privacy audit using existing documentation, interviews and discovery using manual and automated discovery processes.
The audit will cover the following functions and areas :
Business Environment
Identify and document geographic regions, privacy regulations and system locations.
Inventory and Data Classification
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Data Storage /Encryption Requirements
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Data Flows
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Vendors
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Systems
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Data Classifications
Data Protection
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Review protection controls, processes and policies
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Align data classifications with protections
Policies, Processes and Procedures
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Incident Response Plan
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Privacy Policy and Notices
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Data Destruction
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Physical Security
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Third Party Management
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Data Subject Requests
Awareness and Training
Privacy Training within Security Awareness.
Desired outcomes?
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Audit Report detailing current state in each core area and a gap analysis.
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Creation of a remediation plan and timeline
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Executive Summary providing a snapshot of the current situation for distribution to business leaders and committees.