Treatment process and documentation of occurred security incidents

Critical
High
Normal
Low

All security incidents are addressed in a consistent manner to improve security based on what has happened.

In the incident treatment process:

  • the reported incident is confirmed (or found unnecessary to record)
  • the type and cause of incident is documented
  • the risks associated with the incident are documented
  • the risks are re-evaluated and treated if that is necessary after the incident
  • risk mitigation measures or a decision their acceptance is documented
  • people who need to be informed of the results of the incident treatment are identified (including external ones)
  • possible need for a post-incident analysis is determined
Connected other frameworks and requirements:
T06: Turvallisuuspoikkeamien hallinta
32. Security of processing
GDPR
12. Transparent information, communication and modalities for the exercise of the rights of the data subject
GDPR
16.1.5: Response to information security incidents
ISO 27001
DE.AE-2: Analyze detected events
NIST CSF

Reporting personal data breaches to authorities / data subjects

Critical
High
Normal
Low

A personal data breach must be reported to the supervisory authority if the breach may pose a risk to data subjects rights and freedoms. Data subjects, on the other hand, must be informed if the breach is likely to pose a high risk to their rights and freedoms. For example, registrants may take steps to reduce the adverse effect (e.g. by closing their credit card).

The notification must include the following information:

  • a clear description of the personal data breach
  • the name and contact details of the data protection officer or other contact point from which further information can be obtained
  • the likely consequences of the personal data breach
  • the measures proposed or already taken by the controller; where appropriate, measures to mitigate possible adverse effects.
Connected other frameworks and requirements:
33. Notification of a personal data breach to the supervisory authority
GDPR
34. Communication of a personal data breach to the data subject
GDPR
16.1.5: Response to information security incidents
ISO 27001
6.1.3: Contact with authorities
ISO 27001
A.10.1: Notification of a data breach involving PII
ISO 27018

Detailed assessment of the risk of data breach for data subjects

Critical
High
Normal
Low

The controller must assess the risk of the personal data breach to the data subjects. The assessment must take into account, for example, the following:

  • How likely is it that the data will be used to cause harm?
  • What harm could the data be used for (e.g. identity theft, fraud, psychological distress, humiliation or reputational damage)?
  • Nature, sensitivity and amount of personal data
  • How easy it is to identify the registrant using the data?
  • Are there many children or otherwise vulnerable people among the registrants?

The risk assessment affects the urgency and scope of reporting a breach.

Connected other frameworks and requirements:
34. Communication of a personal data breach to the data subject
GDPR
6.1.3: Contact with authorities
ISO 27001
16.1.5: Response to information security incidents
ISO 27001
RS.CO-3: Information sharing
NIST CSF

Process for initiating data breach treatment

Critical
High
Normal
Low

Our organization has pre-defined procedures through which the detected security breach will be addressed. The process may include e.g. the following things:

  • who are part of a team that is ready to respond to breaches
  • how and along what channel the entire team is immediately notified of the breach
  • the team determines the severity (low, medium, high) of the breach based on predefined criteria
  • the breach management is continued with a larger group according to the severity level
Connected other frameworks and requirements:
24. Responsibility of the controller
GDPR
32. Security of processing
GDPR
16.1.5: Response to information security incidents
ISO 27001
16.1.7: Collection of evidence
5.26: Response to information security incidents
ISO 27001
No items found.