I’ve seen a few suppliers make classic errors dealing with breaches in their client’s data. Here are the top three errors suppliers make and 5 suggestions to avoid them!
Purpose Limitation and ROPA
Category: Data Management / Legal Basis Management
Customer:Health & Safety Training organisation
We worked with this health and safe training organisation to ensure that the purpose of processing was documented clearly in their ROPA and to ensure that this lined up with their legal basis for processing. This ensures that for all controller based processing activities the customer is adhering to the purpose limitation requirements of the GDPR which are closely aligned with the legal basis.
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The General Data Protection Regulation is “risk” based legislation. This means that the protective measures an organisation implements should correspond to the level of risk associated with their data processing activities. It’s worth noting that the risk that should be considered here, is the risk to the data subject as opposed to risk to the business of non-compliance.
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.