With the EU GDPR going into effect, the responsibilities of the CISO/Head of Security will shift. This will result in moving Risk Management, Governance, Business Enablement, and Project Delivery Lifecycle to the Data Protection Officer (DPO)/Head of Privacy and having dotted lines to Identity Management and Security Operations.
The role of the DPO will be much like a Compliance Officer, with the additional responsibilities of overseeing sensitive data handling and impacted business processes. We’ve mapped out how the responsibilities will transfer from CISO to DPO.
We’ve taken Data Governance, Identity and Access Management, and Data Migration processes and aligned them with the EU GDPR to outline how long each foundational piece will take to execute.
The current maximum fine in the UK through the Data Protection Act is £500,000, $615,000, or 575,000€. With the EU GPDR there will be a 3,600% increase in the maximum fine to an organization.
Up to 20,000,000 EUR or up to 4% of the annual global revenue of the preceding financial year in the case of an enterprise, whichever is greater.
If the companies below were found non-compliant under the EU GDPR they would have been assessed the following 4% fines based on their 2015 reported global revenue:
PwC recently conducted a survey of 200 CIOs, CISOs, General Counsels, CCOs, CPOs and CMOs from US companies with more than 500 employees. 77% plan to spend $1 million or more on the EU GDPR. Below are 8 ways to outline your budget and prepare for May 25, 2018.
You need to know what sensitive data you have, where it is, and who has access to it. Governance should ensure that access is limited to those who really need it and actual access is checked against this list."
Principles relating to processing of personal data
Responsibility of the controller
Data protection by design and by default
Security of processing
Notification of a personal data breach to the supervisory authority
1. Personal data shall be: (f) processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures (‘integrity and confidentiality’).
1. Taking into account the nature, scope, context and purposes of processing as well as the risks of varying likelihood and severity for the rights and freedoms of natural persons, the controller shall implement appropriate technical and organisational measures to ensure and to be able to demonstrate that processing is performed in accordance with this Regulation. Those measures shall be reviewed and updated where necessary.
1. Taking into account the state of the art, the cost of implementation and the nature, scope, context and purposes of processing as well as the risks of varying likelihood and severity for rights and freedoms of natural persons posed by the processing, the controller shall, both at the time of the determination of the means for processing and at the time of the processing itself, implement appropriate technical and organisational measures, such as pseudonymisation, which are designed to implement data-protection principles, such as data minimisation, in an effective manner and to integrate the necessary safeguards into the processing in order to meet the requirements of this Regulation and protect the rights of data subjects.
2. The controller shall implement appropriate technical and organisational measures for ensuring that, by default, only personal data which are necessary for each specific purpose of the processing are processed. That obligation applies to the amount of personal data collected, the extent of their processing, the period of their storage and their accessibility. In particular, such measures shall ensure that by default personal data are not made accessible without the individual's intervention to an indefinite number of natural persons.
1. Taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, the controller and the processor shall implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk, including inter alia as appropriate:
(b) the ability to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services;
(c) the ability to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident;
(d) a process for regularly testing, assessing and evaluating the effectiveness of technical and organisational measures for ensuring the security of the processing.
2. In assessing the appropriate level of security account shall be taken in particular of the risks that are presented by processing, in particular from accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to personal data transmitted, stored or otherwise processed.
3. The controller and processor shall take steps to ensure that any natural person acting under the authority of the controller or the processor who has access to personal data does not process them except on instructions from the controller, unless he or she is required to do so by Union or Member State law.
1. In the case of a personal data breach, the controller shall without undue delay and, where feasible, not later than 72 hours after having become aware of it, notify the personal data breach to the supervisory authority competent in accordance with Article 55, unless the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons. Where the notification to the supervisory authority is not made within 72 hours, it shall be accompanied by reasons for the delay.