Distributing a phishing exercise to all employees is not advisable to do if your organization has a recurring issue with colleagues not reporting personal data breaches. A phishing exercise is a simulated attack that tests the awareness and response of employees to malicious emails that attempt to obtain sensitive information or compromise systems. While phishing exercises can be useful to train employees on how to recognize and avoid phishing attacks, they are not directly related to the issue of reporting personal data breaches. The other options are more appropriate to address the root cause of the issue, communicate the expectations and procedures for reporting breaches, and provide specific training to areas where breaches are happening
The first step to mitigate further risks when a systems audit uncovers a shared drive folder containing sensitive employee data with no access controls is to restrict access to the folder. This can be done by implementing appropriate access controls, such as user authentication, role-based access, and permissions, to ensure that only authorized individuals can view and access the sensitive data.
A physical control that can limit privacy risk is keypad or biometric access. This is a type of access control that restricts who can enter or access a physical location or device where personal data is stored or processed. Keypad or biometric access requires a code or a biological feature (such as a fingerprint or a face scan) to authenticate the identity and authorization of the person seeking access. This can prevent unauthorized access, theft, loss, or damage of personal data by outsiders or insiders.
'Respond'' in the privacy operational lifecycle includes information requests and privacy rights requests, which are requests from individuals or authorities to access, correct, delete, or restrict the processing of personal data. The privacy program must have processes and procedures to handle such requests in a timely and compliant manner. The other options are not part of the ''respond'' phase, but rather belong to other phases such as ''protect'', ''aware'', or ''align'.
The first stage in the incident response plan under the General Data Protection Regulation (GDPR) for this scenario would be to contain the impact of the breach. This means taking immediate action to stop the unauthorized access or disclosure of personal data, and to prevent it from happening again in the future. This could involve revoking access to the data, notifying the employee who mistakenly sent the data, and implementing security measures to prevent similar breaches from occurring in the future.
When a data breach incident has occurred, the first priority is to determine how to contain the breach. Containment means stopping or minimizing the further loss or unauthorized disclosure of personal data, as well as preserving evidence for investigation and remediation. Containment may involve isolating affected systems, devices, or networks; changing access credentials; blocking malicious IP addresses; or notifying relevant parties such as law enforcement or security experts. After containing the breach, the next steps are to assess the impact and severity of the breach, notify the affected individuals and authorities if required, evaluate the causes and risks of the breach, and implement measures to prevent future breaches.
Privacy audits differ from privacy assessments in that they are evidence-based, meaning that they rely on objective and verifiable data to evaluate the compliance and effectiveness of the privacy program. Privacy assessments, on the other hand, are based on standards, meaning that they use a set of criteria or best practices to measure the performance and maturity of the privacy program. Privacy audits are usually conducted by external parties, while privacy assessments can be done internally or externally.
Crafting policies which ensure minimal data is collected is least likely to be achieved by implementing a Data Lifecycle Management (DLM) program, as it is more related to the data collection stage, not the data management stage. A DLM program focuses on how to handle the data after it has been collected, such as how to store, use, share, and dispose of it. The other options are more likely to be achieved by implementing a DLM program, as they help to optimize the data storage costs, comply with the data retention obligations, and protect the data confidentiality.
If your organization provides a SaaS tool for B2B services and does not interact with individual consumers, and a client's current employee reaches out with a right to delete request, the most appropriate response is to redirect the individual back to their employer to understand their rights and how this might impact access to company tools. This is because your organization is acting as a processor for the client, who is the controller of the employee's personal data.
Distributing a phishing exercise is not advisable when attempting to address the issue of colleagues not reporting personal data breaches. Instead, the recommended steps are to review reporting activity on breaches, improve communication, and provide role-specific training to areas where breaches are happening. These steps will help to ensure that everyone is aware of their responsibilities and that they understand how to report a breach should one occur.
An organization's internal audit team should not implement processes to correct audit failures, as this is the responsibility of the management or the privacy office. The internal audit team should only verify that technical measures are in place, review how operations work in practice, and ensure policies are being adhered to. Implementing corrective actions would compromise the independence and objectivity of the internal audit team
