The Belgian DPA (hereafter referred as CPP, to reflect its official name, Commission for the Protection of Privacy) has issued GDPR-preparation recommendations in the form of 13 guidelines for companies processing personal data. The English-language summary below is taken from a law-firm website (link) (the originals were issued in French (link) and Dutch (link) only).
The good news is that the CPP has now set some priorities, giving data controllers and processors an idea of what the auditors will be looking for in the early days after the GDPR’s effective date. The bad news, at least as I see it, is not only is the guidance mostly vague, but also that there seems to be an embedded assumption that all of this is feasible within a short time frame. Continue reading “Belgian DPA recommends taking 13 steps now”
In my previous post about building a data inventory (link), I showed a basic 3-table schema which stores the names, locations, and other things about the personally-indentifiable information (PII) in a set of databases. This post shows how one might go about recording the actual PII that is in the databases. Continue reading “The Data Inventory, Part 3”
One way to become familiar with the legislation is to read it from beginning to end. Consisting of 88 pages of PDF and over 55,000 words, the GDPR is not a fast read. Nor, having read it, are you likely to hold it in your head. What if you could skip to the parts that are most interesting for you? This post suggests a simple approach to doing just that. Continue reading “What parts of the GDPR are most relevant to you?”
In The Data Inventory, Part 1, we saw how a data inventory can be started with a single-table format in a spreadsheet. In this post we will use relational tables to modify and enhance this design to include additional information about our data to include a global view of all our databases, plus a global view of our data items. Continue reading “The Data Inventory, Part 2”
Let’s get started on something concrete. One of the first things you’ll need to launch your privacy-compliance effort is an inventory of what data you are currently storing. This inventory will be at the core of your efforts, and will be the reference point for stakeholders. In this article I suggest a basic approach to get started using a single table. Future posts will add more tables to provide additional information, so that in the end we have a small schema for our inventory. Continue reading “The Data Inventory, Part 1”
Confronted with the enormity of an effective compliance effort, you are likely to be overwhelmed. For one thing, your resources are likely to be meager. For another, the typical objective at this point is merely informational (“look into it”, “impact assessment”, “cost estimate”). From management’s point of view, this is a reasonable request. From your point of view, it’s not; the information is not lying around, but must be must be collected from dozens or hundreds of applications, databases, filesystems, and more. Continue reading “What to do first”