The goal of the data protection policy
The goal of the data protection policy is to depict the legal data protection aspects in one summarising document. It can also be used as the basis for statutory data protection inspections, e.g., by the customer within the scope of commissioned processing. This is not only to ensure compliance with the European General Data Protection Regulation (GDPR) and Data Protection Act (DPA) 2018 but also to provide proof of compliance.
Security policy and responsibilities in the company
- For a company, in addition to existing corporate objectives, the highest data protection goals are to be defined and documented. Data protection goals are based on data protection principles and must be individually modified for every company.
- Determination of roles and responsibilities (e.g., representatives of the company, operational data protection officers, coordinators or data protection team, and operational managers)
- Commitment to continuous improvement of a data protection management system
- Training, sensitization, and obligation of the employees
The legal framework in the company
- Industry-specific legal or conduct regulations for handling personal data
- Requirements of internal and external parties
- Applicable laws, possibly with special local regulations
Existing technical and organizational measures (TOM)
Appropriate technical and organizational measures must be implemented and substantiated, considering, inter alia, the purpose of the processing, the state of the technology, and the implementation costs.
The description of the implemented TOM can, for example, be based on the structure of ISO/IEC 27002, considering ISO/IEC 29151 (guidelines for the protection of personal data). The respective chapters should be substantiated by referencing the existing guidelines.