Improving safety and security in digital communications: Jeugdzorg Nederland joins forces with Zivver
A large number of administrative actions ensue from the General Data Protection Regulation (in Dutch AVG, in English GDPR) your organisation is still resisting and time is running out. Organisations must bring their operations in line with the GDP before 25 May 2018.
You have undoubtedly already taken the necessary steps to improve data protection within your municipality. But perhaps this is not enough for compliance with the GDPR. How can you be sure that you are meeting all the requirements? Keeping an overview is important in this respect. In this blog we provide a clear picture of the steps you need to take in order to be ready for the new law.
Start by putting together the right team. The ideal core team consists of a lawyer, a privacy expert and an IT professional. They involve the responsible managers and content specialists in each department.
1. Gaining insightMap all data flows. As there can be a lot of these, it is sensible to start with the most important or most sensitive data streams. This provides insight into the structure and infra systems of the municipality. Questions you have to ask in this context include:
- What data are we collecting, at which location?
- Where and how do we store these data?
- Who receives or has access to these data?
This enables you to gain insight into the infrastructure and systems of your organisation.
2. Determine the impact on the organisation
In order to properly assess the impact of these data streams, and therefore the risk associated with them, you first need to know how sensitive the data are. Every municipality processes large quantities of privacy-sensitive data. You are required to log these data in a processing register. This forces you to think about what personal data you store, their purpose, retention period and security. If you set up the processing register in accordance with the guidelines, you fulfil the obligation to register within the GDPR.
When all data flows, including the impact of the data, have been mapped, the team checks them against the GDPR by means of a gap analysis. You compare the current situation with the desired situation. This results in measures to fill the gaps. In some cases, internal guidelines are already available for this, which you can update. In other cases it is necessary to draw up new rules.
3. Forming and maintaining policy
Our GDPR Checklist contains the necessary steps towards GDPR compliance. It addresses in greater detail the drafting of a processing agreement, obtaining permission for the processing of personal data, the security measures to be taken and the obligation to report data leaks.