Category: Change Management / Transparency / Security Management
Customer: Industry user group for a software supplier
We were asked by an industry user group for a software supplier to carry out a DPIA on behalf of all the controller clients for a new mobile app being developed that would be deployed to their end customers. We carried out a DPIA in close co-operation with the software supplier. Given that the app would be rolled out by an estimated 50-75 user group controllers in the first year with an estimated end user base of between 1,500 – 10,000 users per deployment we needed to ensure that the default app configuration would be robust, and that the user group was given adequate information to deploy the app in a compliant manner. In the end, we carried out a DPIA and also produced documented sub-processor evaluations, a transparency review of the app and we developed a rollout guide for the app to be used by each of the controller clients. The app developer also implemented additional measures including regular pen testing of the app and a deployment checklist.
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Data Protection Programmes are all the rage these days. It’s great to see the compliance conversation moving in this direction. As a Data Protection Officer (DPO), I know the difference between working with a solid data protection programme and working with none and all.
Supplier due diligence is one of those exercises we think we will get around to eventually. Here’s a real story that illustrates how a supplier can let you down.
