GDPR IRL - Policy Mapping

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The document discusses policies and procedures related to GDPR compliance.

Reference IDs and data processing activities are repeated on many pages

Policies for data protection, security, privacy, breaches and more are discussed

Reference ID Criteria Tie Request Type

5(1)
GDPR - 1 24(2) G
91(1)
GDPR - 2 5(1) G
GDPR - 3 5(1) G
GDPR - 4 5(1) G
5(1)
GDPR - 5 G
30(1)(2)(3)

6 (4)
GDPR - 6 13(3) G
14(4)
GDPR - 7 5(1) G
8(2)
GDPR - 8 G
12(1)
9(2)
GDPR - 9 G
10 (1)
GDPR - 10 6(1) G

5(1)
GDPR - 11 6(4) G
25(2)
35(1)(7)(9)

6 (4)
GDPR - 12 7 (1)(2) G
8 (1)

7 (3)
GDPR - 13 18 (1)(3) G
19
21(1)(3)(4)

GDPR - 14 9 G

12(1)(2)(3)(4)(5)(6)
GDPR - 15 13(1)(2) G
14 (1)(2)

12(1)(2)(3)(4)(5)(6)
GDPR - 16 22(1)(2)(3)(4) G

GDPR - 17 12(1)(2)(3)(4)(5)(6) G
13 (1)(2)
GDPR - 18 14(3) G
21(4)
GDPR - 19 15 (1)(2)(3)(4) G
16
GDPR - 20 G
19
16
GDPR - 21 G
19
17(1)(2)
GDPR - 22 19 G

GDPR - 23 20(1) G
GDPR - 24 21(2) G
21(6)
GDPR - 25 89(2) G

GDPR - 26 24(3) G

GDPR - 27 25(1) G

GDPR - 28 27(1) G

28(1)(2)(3)(4)(5)(9)
GDPR - 29 29 G
32(4)

GDPR - 30 31(1) G

GDPR - 31 32(1) G

33(1)
GDPR - 32 G
34(3)
GDPR - 33 33(5) G

GDPR - 34 36(1) G

33(1)(2)(3)
GDPR - 35 G
34(1)(2)
37(1)(5)(7)
GDPR - 36 G
38(2)(4)(5)

GDPR - 37 39(1)(2) G

GDPR - 38 44-49 G

GDPR - 39 89(1) G
Request
Data Privacy Policies and procedures

Information security policies and procedures


Data quality maintenance policies and procedures.
Data processing procedures (legal basis, Codes of Conduct, policies and other
measures)
Personal data inventory / Data Processing Activities Mapping (What personal data is
held and where)
Policies and procedures for secondary uses of personal data (legal basis, Codes of
Conduct, policies and other measures), if applicable.

Records retention policies and procedures


Policies and procedures for collection and use of children and minors’ data

Policies and procedures for collection and use of sensitive personal data (including
biometric and genetic data)
Documented legal basis for processing personal data (MSA with Data Controller,
etc.)
Please provide the most recent Data Protection Impact Assessment

**May not be required depending on nature of the processing activity**

Please provide evidence to support how valid consent is obtained. (How is consent
obtained from data subjects prior to processing their data?)

Please provide procedures to evidencing how the entity responds to requests to


opt-out, restrict or object to processing.

Data processing activities and classification standards to determine if special


categories of data are identified (e.g. racial or ethnic origin, political opinions, etc.)
Data privacy notice that details the organization’s personal data handling practices

Policies and procedures to review processing conducted wholly or partially by


automated means.
Breach notification policy and procedure(to affected individuals) and reporting (to
regulators, credit agencies, law enforcement) and protocol
Data Subject Collections Notice

Polices and procedures to respond to requests for access to personal data


Policies and procedures to respond to requests and/or provide a mechanism for
individuals to update or correct their personal data
Policies and procedures of communicating any rectification of erasure of personal
data.
Policies and procedures to respond to requests to be forgotten or for erasure of
data
Policies and procedures to respond to requests for data portability
Data privacy notice integrated into direct marketing
Data privacy notice integrated into research practices, if applicable.

Please provide evidence of any privacy certifications currently maintained, if any.


Please provide evidence to support that Privacy by Design is integrated into system
and product development.
Please provide evidence supporting that the responsibility of Data Privacy to a
designated individual in the EU, should Article 3(2) apply.
Please provide evidence of the third-party security requirements included in
executed agreements/contracts with third-parties (e.g., clients, vendors, processors,
affiliates)

Policies and procedures to cooperate with supervisory authorities, if not contained


within previously provided policy.
Please provide evidence to support that appropriate technical safeguards are in place to
mitigate the risks that are presented by processing, in particular from accidental or unlawful
destruction, loss, alteration, unauthorized disclosure of, or access to personal data
transmitted, stored or otherwise processed.

Ex. Firewall Configurations, Backup Configurations, Enterprise System Monitoring


Configurations, System Event Logs, Data Encryption Configurations, etc. )

Data Privacy Incident Response Policy and Procedures

Data privacy incidents/breaches log for the review period


Please provide evidence to support that supervisory authorities are / will be
consulted prior to processing when the results of the DPIA result in a high risk in the
absence of measures taken by the controller to mitigate the risk.

**Only applicable if you are required to complete a DPIA***

Data breach notification policies and procedures


Data Protection Officer (DPO) formal assignment, if applicable.

Data protection officer 's job responsibilities/description including:


- Privacy training
-self-assessments of privacy management
- Enterprise Privacy Risk Assessment
- ongoing privacy compliance requirements, e.g., law, case law, codes, etc.
- PIA/DPIA guidelines and templates

Please provide policies records of the transfer mechanism used for cross-border
data flows (e.g., standard contractual clauses, binding corporate rules, approvals
from regulators)

-Binding Corporate Rules as a data transfer mechanism

-Contracts as a data transfer mechanism (e.g., Standard Contractual Clauses)

-The EU-US Privacy Shield as a data transfer mechanism

**Only applicable if data is transferred to another country**

Policies/procedures for the de-identification of personal data if the processing is


related to the archiving purposes in the public interest, scientific or research
purposes, or statistical purposes.
Policy Document / GDPR Requirement
External Privacy Notice on the website and the "GDPR Compliance Policy" to be created
from the attached example.

Information Security Policies and Procedures from the provided templates.


See Section 4.4.4 - Data Quality
External Privacy Notice on the website and the "GDPR Compliance Policy" to be created
A-LIGN working to complete with the data owners.

This should be defined within the "GDPR Compliane Policy", however more than likely is
going to be Not Applicable, but this should still be defined.

Information Security Policies and Procedures from the provided templates.


This is more than likely going to be Not Applicable, but this should still be defined within
the "GDPR Compliance Policy"
See Section 4.4 - Data Use

See Section 4.4 - Data Use


See Section 4.1.3 - Data Protection by Design;
See Data Impact Assessment (DPIA) Guidance in attached document

See Section 4.4 - Data Use

See 4.7 Data Suject Requests

See Section 4.4 - Data Use

External Privacy Notice on the website

See 4.4.5 Profiling & Automated Decision-Making

See 4.12 - Breach Reporting;


See incident response program within the information security templates attached.
See 4.7 Data Suject Requests
See 4.7 Data Suject Requests

See 4.7 Data Suject Requests

See 4.7 Data Suject Requests

See 4.7 Data Suject Requests


See 4.4.6 Direct Marketing
Not Applicable

Not Applicable
See 4.1.3 Data Protection by Design

See 4.1.2 Policy Dissimenation and Enforcement

See Governance within the sample GDPR Policy.

Information Security Policies and Procedures from the provided templates.

See Section 4.12 within the sample GDPR Policy and the incident response policy within
the Information Security Templates.
Not Applicable

See Governance within the sample GDPR Policy.

See Section 4.12 within the sample GDPR Policy and the incident response policy within
the Information Security Templates.
See Governance within the sample GDPR Policy.

See Governance within the sample GDPR Policy.

Not Applicable

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