PRIV- 30 – Data Protection Policy

What is this control about?

Implementing the control ‘Data Protection Policy’ is crucial for organizations to establish a comprehensive framework that outlines how personal data is collected, processed, stored, and protected throughout the data lifecycle. This policy serves as a guiding document that sets the standards, principles, and procedures for handling personal data in a secure and compliant manner.

Available tools in the marketplace

Tools:

N/A – No tools recommendation

Available templates

TrustCloud has a curated list of templates internally or externally sourced to help you get started. Click on the link for a downloadable version:

• Data Protection Policy Template

Control implementation

Here are some guidelines to implement a Data Protection program:

• Policy Development: Assemble a cross-functional team, including IT, legal, compliance, and data privacy experts. Review applicable data protection regulations and industry standards to draft a comprehensive Data Protection Policy tailored to the organization’s needs.
• Policy Approval and Communication: Present the drafted policy to management and obtain necessary approvals. Communicate the policy to all relevant stakeholders, employees, and third-party vendors who handle personal data. Conduct training sessions to ensure understanding and compliance.
• Data Inventory and Mapping: Create an inventory of all data collected, processed, and stored within the organization. Map the flow of data to identify its lifecycle, from collection to disposal. Determine the data’s sensitivity and the purposes for which it is used.
• Risk Assessment: Perform a risk assessment to identify potential data privacy and security risks associated with the organization’s data processing activities. Evaluate existing controls and identify gaps that need to be addressed to align with the policy.
• Data Handling Procedures: Develop detailed procedures for data handling, including data collection, storage, access, sharing, transfer, and disposal. Ensure that these procedures align with the policy’s principles and comply with relevant data protection laws.
• Consent and Data Subject Rights: Establish processes to obtain and manage data subjects’ consent for data processing activities. Implement procedures for handling data subject rights requests, such as access, rectification, erasure, and data portability.
• Security Measures: Define security measures to protect personal data from unauthorized access, disclosure, alteration, and destruction. Implement encryption, access controls, firewalls, and monitoring tools to safeguard sensitive information.
• Third-Party Management: Assess and monitor third-party vendors that process personal data on behalf of the organization. Ensure that these vendors adhere to the Data Protection Policy and comply with relevant regulations.

What evidence do auditors look for?

Most auditors, at a minimum, are looking for the below-suggested action:

• Data Protection Policy Document: The primary evidence is the official Data Protection Policy document itself. This document should clearly outline the organization’s commitment to protecting personal data, the scope of the policy, data handling procedures, roles and responsibilities, data subject rights, and the organization’s approach to complying with data protection laws and regulations.
• Policy Approval and Review Records: Auditors will seek evidence of the policy’s approval, including signatures of senior management or the board of directors. Additionally, they would look for records of policy reviews and updates to ensure that the policy remains current and relevant to changing regulatory requirements.

Evidence example

For the suggested action, an example is provided below:

• Data Protection Policy Document

Use Data Protection Policy Template