Technical and organizational measures

The European General Data Protection Regulation (GDPR) has been in effect since May 25, 2018. In addition to the creation of:

  • Privacy policies
  • Records of processing activities
  • Data Processing Agreements (DPAs)

The controller must also define the technical and organizational measures.

What is the purpose of technical and organizational measures?

The technical and organizational measures ensure that personal data processed by the controller is protected from unauthorized access in both IT systems and physical records.

The scope of the measures depends on various factors:

  • The number of data / affected individuals
  • The purpose of the processing,
  • The likelihood of a risk occurring
  • The impact on an individual in the event of harm

Which data needs to be protected?

The EU GDPR stipulates that all personal data must be identified and subjected to a risk analysis in accordance with Article 32(1) of the GDPR. Special categories of personal data must be protected with enhanced measures.

The different likelihood and severity of the risk to the rights and freedoms of a natural person must be assessed.

Which measures must be implemented for which systems?

To determine this, a list of all IT systems is required.
In which IT systems is personal data stored?
Is there a distinction for special categories of personal data?

The risk analysis is conducted using the factors of the CIA triad.

carried out.

  • C – Confidential
    Confidentiality: Information may only be read by previously authorized users.
  • I – Integrity
    Integrity: Refers to ensuring the accuracy of the data.
  • A – Availability
    Availability: IT systems should be operational at all times.

How do I create a risk analysis?

The selected assets (company values) are now considered according to the criteria.

  • Access Control
    Building perimeter
    Video surveillance
    Locked office
    Electronic access control
  • Access Protection
    Authentication methods
    Network segmentation
    Personalized access
    Firewall
    Antivirus software
  • Access Control
    Authorization concept
    Complex passwords
  • Separation Control
    Multi-tenancy capability
  • Transfer Control
    Encryption options
    Email encryption
  • Input Control
    Logging
  • Availability
    Disaster recovery plan
    Backups
    Redundant power supply design
  • Review/Assessment
    Regular technical and organizational system audits
  • Data Processing
    Written instructions from the client

Now, based on the current values, a scenario is developed in which the exploitation of a technical vulnerability or the absence of an organizational instruction within the company could lead to an unintended data release.

The likelihood of the scenario occurring is assessed, as well as the extent of the damage in the event it happens. The resulting calculated risk provides information about the personnel and financial resources needed to enhance the protection of the data.

Example: Risk Analysis

Do all measures have to be implemented?

The measures identified in the risk analysis are now evaluated, assigned, and time-limited in the action list.

This action list provides the authority with information about everything you have planned. Reasons are described in the action list.

Warum ist es nicht zur Umsetzung gekommen?
Warum findet die Umsetzung erst in 2 Jahren statt.

Die technischen Maßnahmen wie:

  • Firewall
  • Virensoftware
  • Intrusion Detection System
  • Mobile Device Management
  • Remote Monitoring Management
  • Backup Konzept

can be tested and implemented in cooperation with your IT system house.

The organizational measures are presented in the data protection management system. They cover the following topics:

  • Handling of personal data
  • Handling of mobile devices
  • Internet usage
  • Working from home
  • Protection of devices while traveling
  • Clean desk policy
  • Deletion of data carriers

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Standard Data Protection Model

The Standard Data Protection Model is a method with which technical and organizational measures can be established. The following measures can be generated from this model:

Technical measures:

  • Structural changes to implement physical security
  • Changes to the network infrastructure or outsourcing of data
  • Video surveillance
  • Access control system
  • Firewall
  • Intrusion Detection System (IDS)
  • Antivirus software
  • Commissioning of a logging server
  • Implementation of encryption methods

The implementation of the measures can be carried out by in-house system administrators or by an external service provider, in compliance with the principles of "privacy by design" and "privacy by default."

Organizational measures are:

  • Introduction of an information security policy
  • Implementation of a training concept
  • Process definition for granting access permissions
  • Development of an authorization concept
  • Process for managing cryptographic keys
  • Guidelines for the disposal/removal of operating resources
  • Change management
  • Vulnerability management
  • Process for responding to data security incidents
  • Compliance and continuous improvement as well as conformity of your data security management system

The organizational measures should be reviewed annually by an independent auditor. However, it is not necessary to involve an accredited body for an official certification.

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