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General Data Protection Regulation
32. Security of processing

How to fill the requirement

General Data Protection Regulation

32. Security of processing

Task name
Priority
Status
Theme
Policy
Other requirements
Data system listing and owner assignment
Critical
High
Normal
Low
Fully done
Mostly done
Partly done
Not done
System management
Data system management
44
requirements

Examples of other requirements this task affects

5. Principles relating to processing of personal data
GDPR
24. Responsibility of the controller
GDPR
28. Data processor
GDPR
32. Security of processing
GDPR
44. General principle for transfers
GDPR
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Data system listing and owner assignment
1. Task description

Organisation must maintain a listing of used data systems and their owners. Owner is responsible for completing the related documentation and possible other security actions directly related to the data system.

Data system documentation must include at least:

  • System purpose and linked responsibilities
  • System's data location (covered in a separate task)
  • System's maintenance and development responsibilities and linked partners (covered in a separate task)
  • When necessary system's access roles and authentication methods (covered in a separate task)
  • When necessary systems interfaces to other systems (covered in a separate task)
Staff guidance and training procedure in cyber security
Critical
High
Normal
Low
Fully done
Mostly done
Partly done
Not done
Personnel security
Cyber security training
41
requirements

Examples of other requirements this task affects

29. Processing under the authority of the controller or processor
GDPR
32. Security of processing
GDPR
7.2.1: Management responsibilities
ISO27 Full
7.2.2: Information security awareness, education and training
ISO27 Full
4 §: Tiedonhallinnan järjestäminen tiedonhallintayksikössä
TiHL
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Staff guidance and training procedure in cyber security
1. Task description

Our organization has defined procedures for maintaining staff's cyber security awareness.These may include e.g. the following things:

  • staff receive instructions describing the general guidelines of digital security related to their job role
  • staff receive training to maintain the appropriate digital and cyber security skills and knowledge required for the job role
  • staff demonstrate through tests that they have the security skills and knowledge required for the job role

Training should focus on the most relevant security aspects for each job role and include often enough the basics, which concern all employees:

  • employee's personal security responsibilities (e.g. for devices and processed data)
  • policies relevant for everyone (e.g. security incident reporting)
  • guidelines relevant for everyone (e.g. clean desk)
  • organization's security roles (who to contact with problems)
Treatment process and documentation of occurred security incidents
Critical
High
Normal
Low
Fully done
Mostly done
Partly done
Not done
Incident management
Incident management and response
42
requirements

Examples of other requirements this task affects

12. Transparent information, communication and modalities for the exercise of the rights of the data subject
GDPR
32. Security of processing
GDPR
16.1.5: Response to information security incidents
ISO27 Full
T06: Turvallisuuspoikkeamien hallinta
Katakri
6.4: Menettelytavat virhe- ja ongelmatilanteissa
Self-monitoring
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Treatment process and documentation of occurred security incidents
1. Task description

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
Personnel guidelines for safe data system and authentication info usage
Critical
High
Normal
Low
Fully done
Mostly done
Partly done
Not done
System management
Data system management
27
requirements

Examples of other requirements this task affects

29. Processing under the authority of the controller or processor
GDPR
32. Security of processing
GDPR
9.3: User responsibilities
ISO27 Full
8.1.3: Acceptable use of assets
ISO27 Full
9.1.1: Access control policy
ISO27 Full
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Personnel guidelines for safe data system and authentication info usage
1. Task description

The organization should have defined guidelines for the generally acceptable use of data systems and for the management of the necessary credentials.

In addition, the owners of data systems classified as 'High' or 'Critical' priority can define, document, and implement more specific guidelines for the use of that particular data system. These guidelines can describe e.g. security requirements related to the data contained in the system.

Regular reviewing of data system access rights
Critical
High
Normal
Low
Fully done
Mostly done
Partly done
Not done
System management
Access control and authentication
26
requirements

Examples of other requirements this task affects

5. Principles relating to processing of personal data
GDPR
24. Responsibility of the controller
GDPR
32. Security of processing
GDPR
9.2.5: Review of user access rights
ISO27 Full
16 §: Tietojärjestelmien käyttöoikeuksien hallinta
TiHL
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Regular reviewing of data system access rights
1. Task description

Data system owner determines the access roles to the system in relation to the tasks of users. The compliance of the actual access rights with the planned ones must be monitored and the rights reassessed at regular intervals.

When reviewing access rights, care must also be taken to minimize admin rights and eliminate unnecessary accounts.

Designation of data set owners
Critical
High
Normal
Low
Fully done
Mostly done
Partly done
Not done
Management of data sets
Management of data sets
11
requirements

Examples of other requirements this task affects

32. Security of processing
GDPR
8.1.2: Ownership of assets
ISO27 Full
18.1.3: Protection of records
ISO27 Full
13 §: Tietoaineistojen ja tietojärjestelmien tietoturvallisuus
TiHL
15 §: Tietoaineistojen turvallisuuden varmistaminen
TiHL
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Designation of data set owners
1. Task description

An owner is assigned to each data set. The owner is responsible for the life cycle of the information asset and is responsible for performing the management tasks related to that asset.

The owner's duties include e.g.:

  • ensuring the documentation of asset
  • ensuring appropriate protection of asset
  • regularly reviewing access rights
  • ensuring proper handling of information, also on disposal

The owner can delegate some of the tasks, but the responsibility remains with the owner.

General security competence and awareness of personnel
Critical
High
Normal
Low
Fully done
Mostly done
Partly done
Not done
Risk management and leadership
Cyber security management
21
requirements

Examples of other requirements this task affects

29. Processing under the authority of the controller or processor
GDPR
32. Security of processing
GDPR
7.2.1: Management responsibilities
ISO27 Full
7.2.2: Information security awareness, education and training
ISO27 Full
PR.AT-1: Awareness
NIST
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General security competence and awareness of personnel
1. Task description

Personnel under the direction of the entire organization must be aware:

  • how they can contribute to the effectiveness of the information security management system and the benefits of improving the level of information security
  • the consequences of non-compliance with the requirements of the information security management systemwhich roles in the personnel have effects to the level of security

In addition, top management has defined ways in which personnel are kept aware of security guidelines related to their own job role.

Process for initiating data breach treatment
Critical
High
Normal
Low
Fully done
Mostly done
Partly done
Not done
Incident management
Data breach management
9
requirements

Examples of other requirements this task affects

24. Responsibility of the controller
GDPR
32. Security of processing
GDPR
16.1.5: Response to information security incidents
ISO27 Full
16.1.7: Collection of evidence
ISO27 Full
5.26: Response to information security incidents
ISO27k1 Full
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Process for initiating data breach treatment
1. Task description

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
Amount, competence and adequacy of key cyber security personnel
Critical
High
Normal
Low
Fully done
Mostly done
Partly done
Not done
Risk management and leadership
Cyber security management
22
requirements

Examples of other requirements this task affects

32. Security of processing
GDPR
37. Designation of the data protection officer
GDPR
6.1.1: Information security roles and responsibilities
ISO27 Full
T03: Turvallisuustyön resurssit
Katakri
ID.GV-2: Cybersecurity role coordination
NIST
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Amount, competence and adequacy of key cyber security personnel
1. Task description

The organization shall have a sufficient number of trained, supervised and, where necessary, properly security cleared personnel who play key roles in information security, performing management tasks related to the information security management system.

The organization has defined:

  • what qualifications this staff should have
  • how qualifications are acquired and ensured (e.g. through appropriate training and training monitoring)
  • how qualifications can be demonstrated through documentation

The owner of the task regularly reviews the number and level of competence of the security personnel.

Monitoring suppliers' compliance with security requirements
Critical
High
Normal
Low
Fully done
Mostly done
Partly done
Not done
Partner management
Agreements and monitoring
24
requirements

Examples of other requirements this task affects

32. Security of processing
GDPR
15.1.1: Information security policy for supplier relationships
ISO27 Full
15.2.1: Monitoring and review of supplier services
ISO27 Full
ID.GV-2: Cybersecurity role coordination
NIST
ID.SC-1: Cyber supply chain
NIST
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Monitoring suppliers' compliance with security requirements
1. Task description

A designated responsible person actively monitors the supplier's activities and services to ensure compliance with the security terms of the contracts and the proper management of security incidents.

Monitoring includes the following:

  • monitoring the promised service level
  • reviewing supplier reports and arranging follow-up meetings
  • regular organization of independent audits
  • follow-up of problems identified in audits
  • more detailed investigation of security incidents and review of related documentation
  • review of the supplier's future plans (related to maintaining the service level)
Avoiding and documenting shared user accounts
Critical
High
Normal
Low
Fully done
Mostly done
Partly done
Not done
System management
Access control and authentication
11
requirements

Examples of other requirements this task affects

32. Security of processing
GDPR
9.2.4: Management of secret authentication information of users
ISO27 Full
I07: Tietojenkäsittely-ympäristön toimijoiden tunnistaminen
Katakri
TEK-08: Tietojenkäsittely-ympäristön toimijoiden tunnistaminen
Julkri
5.16: Identity management
ISO27k1 Full
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Avoiding and documenting shared user accounts
1. Task description

Shared accounts should only be allowed if they are necessary for business or operational reasons and should be separately approved and documented.

If shared accounts are used for admin purposes, passwords must be changed as soon as possible after any user with admin rights leaves their job.

Privacy-related codes of conduct and certification
Critical
High
Normal
Low
Fully done
Mostly done
Partly done
Not done
Privacy
Processing principles and accountability
2
requirements

Examples of other requirements this task affects

32. Security of processing
GDPR
TSU-15: Osoitusvelvollisuus
Julkri
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Privacy-related codes of conduct and certification
1. Task description

GDPR encourages the introduction of a number of general codes of conduct and certification mechanisms, data protection shields and marks, especially at the European Union level.

The idea behind all of these is to show that the processing is in line with good data processing and data protection requirements. The European Data Protection Council will gather all available certification mechanisms publicly available.

Pseudonymisation of personal data
Critical
High
Normal
Low
Fully done
Mostly done
Partly done
Not done
Privacy
Privacy by design and default
2
requirements

Examples of other requirements this task affects

32. Security of processing
GDPR
8.11: Data masking
ISO27k1 Full
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Pseudonymisation of personal data
1. Task description

Pseudonymisation means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information.

Anonymization of personal data
Critical
High
Normal
Low
Fully done
Mostly done
Partly done
Not done
Privacy
Privacy by design and default
2
requirements

Examples of other requirements this task affects

32. Security of processing
GDPR
8.11: Data masking
ISO27k1 Full
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Anonymization of personal data
1. Task description

Anonymisation means modifying personal information so that the person can no longer be identified from it. For example, data can be roughened to a general level or data about an individual can be deleted. Identification is irreversibly prevented in anonymisation, in contrast to pseudonymisation, where data can be restored to their original form using additional information.

Minimization of information outside data systems
Critical
High
Normal
Low
Fully done
Mostly done
Partly done
Not done
Management of data sets
Management of data sets
7
requirements

Examples of other requirements this task affects

32. Security of processing
GDPR
8.1.3: Acceptable use of assets
ISO27 Full
8.3.1: Management of removable media
ISO27 Full
9.4.4: Use of privileged utility programs
ISO27 Full
A.11.2: Restriction of the creation of hardcopy material
ISO 27018
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Minimization of information outside data systems
1. Task description

A large amount of valuable information in an organization has often accumulated over time into hard-to-find and manageable unstructured data — excels, text documents, intranet pages, or emails.

Once this information has been identified, a determined effort can be made to minimize its amount.Important data outside data systems is subject to one of the following decisions:

  • move into a data system
  • get rid of (when the information is old, no longer necessary or otherwise irrelevant)
  • is kept in use and a responsible person is appointed to manage the risks
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1.1 (MIL2): Manage IT and OT Asset Inventory
C2M2: MIL1
1.1 (MIL3): Manage IT and OT Asset Inventory
C2M2: MIL1
1.1.1: Availability of information security policies
TISAX
1.1.1: Identify the organisation’s strategy and priorities
NSM ICT-SP
1.1.2: Identify the organisation’s structures and processes for security management
NSM ICT-SP
1.1.3: Identify the organisation’s processes for ICT risk management
NSM ICT-SP
1.1.4: Identify the organisation’s tolerances for ICT risk
NSM ICT-SP
1.1.5: Identify the organisation’s deliverables, information systems and supporting ICT functions
NSM ICT-SP
1.1.6: Identify information processing and data flow
NSM ICT-SP
1.2 (MIL2): Manage Information Asset Inventory
C2M2: MIL1
1.2 (MIL3): Manage Information Asset Inventory
C2M2: MIL1
1.2.1: Establish a process to identify devices and software in use at the organisation
NSM ICT-SP
1.2.1: Scope of Information Security management
TISAX
1.2.2: Establish organisational guidelines for approved devices and software
NSM ICT-SP
1.2.2: Information Security Responsibilities
TISAX
1.2.3: Identify devices in use at the organisation
NSM ICT-SP
1.2.3: Information Security requirements in projects
TISAX
1.2.4: Definition of responsibilities with service providers
TISAX
1.2.4: Identify the software in use at the organisation
NSM ICT-SP
1.2: Manage Information Asset Inventory
C2M2: MIL1
1.3 (MIL2): Manage IT and OT Asset Configuration
C2M2: MIL1
1.3 (MIL3): Manage IT and OT Asset Configuration
C2M2: MIL1
1.3.1: Identification of information assets
TISAX
1.3.1: Identify the users of the information systems
NSM ICT-SP
1.3.2: Classification of information assets
TISAX
1.3.2: Identify and define the different user categories
NSM ICT-SP
1.3.3: Identify roles and responsibilities linked especially to ICT security
NSM ICT-SP
1.3.3: Use of approved external IT services
TISAX
1.3.4: Use of approved software
TISAX
1.3: Manage IT and OT Asset Configuration
C2M2: MIL1
1.4 (MIL2): Manage Changes to IT and OT Assets
C2M2: MIL1
1.4 (MIL3): Manage Changes to IT and OT Assets
C2M2: MIL1
1.4.1: Management of Information Security Risks
TISAX
1.4: Manage Changes to IT and OT Assets
C2M2: MIL1
1.5 (MIL1): Management Activities for the ASSET domain
C2M2: MIL1
1.5 (MIL2): Management Activities for the ASSET domain
C2M2: MIL1
1.5 (MIL3): Management Activities for the ASSET domain
C2M2: MIL1
1.5.1: Assessment of policies and requirements
TISAX
1.5.2: External review of ISMS
TISAX
1.5: Management Activities for the ASSET domain
C2M2: MIL1
1.6.1: Reporting of security events
TISAX
1.6.2: Management of reported events
TISAX
1.6.3: Crisis preparedness
TISAX
10 §: Johdon vastuu
KyberTL
10. Processing of personal data relating to criminal convictions and offences
GDPR
10.1 (MIL2): Establish Cybersecurity Program Strategy
C2M2: MIL1
10.1 (MIL3): Establish Cybersecurity Program Strategy
C2M2: MIL1
10.1.1: Policy on the use of cryptographic controls
ISO27 Full
10.1.2: Key management
ISO27 Full
10.1.2: Key management
ISO 27017
10.1: Continuous improvement
ISO27k1 Full
10.1: Cryptographic controls
ISO27 Full
10.1: Cryptographic controls
ISO 27017
10.1: Establish Cybersecurity Program Strategy
C2M2: MIL1
10.2 (MIL2): Establish and Maintain Cybersecurity Program
C2M2: MIL1
10.2 (MIL3): Establish and Maintain Cybersecurity Program
C2M2: MIL1
10.2: Establish and Maintain Cybersecurity Program
C2M2: MIL1
10.2: Non-conformity and corrective action
ISO27k1 Full
10.3 (MIL1): Management Activities for the PROGRAM domain
C2M2: MIL1
10.3 (MIL2): Management Activities for the PROGRAM domain
C2M2: MIL1
10.3 (MIL3): Management Activities for the PROGRAM domain
C2M2: MIL1
10.3: Management Activities for the PROGRAM domain
C2M2: MIL1
10: Cryptography
ISO27 Full
10: Cryptography
ISO 27017
10: Cybersecurity Program Management (PROGRAM)
C2M2: MIL1
10: Prosessi väärinkäytöksiin reagoimiseksi
Sec overview
11 §: Poikkeamailmoitukset viranomaiselle
KyberTL
11. Processing which does not require identification
GDPR
11.1.1: Physical security perimeter
ISO27 Full
11.1.2: Physical entry controls
ISO27 Full
11.1.3: Securing offices, rooms and facilities
ISO27 Full
11.1.4: Protecting against external and environmental threats
ISO27 Full
11.1.5: Working in secure areas
ISO27 Full
11.1.6: Delivery and loading areas
ISO27 Full
11.1: Secure areas
ISO27 Full
11.2.1: Equipment siting and protection
ISO27 Full
11.2.2: Supporting utilities
ISO27 Full
11.2.3: Cabling security
ISO27 Full
11.2.4: Equipment maintenance
ISO27 Full
11.2.5: Removal of assets
ISO27 Full
11.2.6: Security of equipment and assets off-premises
ISO27 Full
11.2.7: Secure disposal or re-use of equipment
ISO27 Full
11.2.7: Secure disposal or re-use of equipment
ISO 27017
11.2.8: Unattended user equipment
ISO27 Full
11.2.9: Clear desk and clear screen policy
ISO27 Full
11.2: Equipment
ISO27 Full
11.2: Equipment
ISO 27017
11: Digiturvan mittarien määrittäminen
Sec overview
11: Physical and environmental security
ISO27 Full
11: Physical and environmental security
ISO 27017
12 §: Luotettavuutta edellyttävien tehtävien tunnistaminen ja luotettavuudesta varmistuminen
TiHL
12 §: Poikkeamaa koskeva väliraportti
KyberTL
12. Transparent information, communication and modalities for the exercise of the rights of the data subject
GDPR
12.1.1: Documented operating procedures
ISO27 Full
12.1.2: Change management
ISO27 Full
12.1.3: Capacity management
ISO27 Full
12.1.4: Separation of development, testing and operational environments
ISO27 Full
12.1: Operational procedures and responsibilities
ISO27 Full
12.2.1: Controls against malware
ISO27 Full
12.2: Protection from malware
ISO27 Full