Information security management in data protection laws is akin to conducting a grand symphony – each instrument, or in this case, each aspect of data processing plays a critical role in creating a harmonious outcome. Striking the right chord is especially crucial when personal data is at stake, given its attractiveness to data predators lurking in the shadows.

Setting the tempo: Understanding data processing relationships

Organisations often play different roles in a data processing chain, like a symphony of various instruments. A responsible party sets the tempo, instructing a processor who may, in turn, guide a sub-processor. The score of data protection laws binds these roles and contracts like Data Processing Agreements (DPAs). Every note or clause in these agreements must be precise and clear, creating a harmonious melody that safeguards personal data by preventing unauthorised access.

Orchestrating robust information security management in terms of data protection laws

The heart of any DPA should beat with robust security measures choreographed to prevent unauthorised access to sensitive data. Much like a conductor coordinating a symphony’s various sections, organisations must harmonise technical standards like physical and digital safeguards with organisational measures, such as training and operational safeguards. This includes having the relevant information security annexures to specify these safeguards.

“In a symphony of data processing, every note must be precise, every instrument tuned, and every beat synchronised.”

Embracing globally accepted information security practices

To orchestrate a triumphant symphony, a conductor relies on a well-composed score. GDPR and the ISO 27000 suite of standards offer such a score in information security management. These globally accepted practices provide the structure for establishing an information security management system, with ISO 27001:2013 focusing on system requirements, ISO 27002:2022 on security controls, and ISO 27701:2019 on privacy information management.

Conducting a multi-disciplinary approach to information security

A symphony is not just about string or wind instruments but the harmony created by all these diverse elements. Similarly, information security management isn’t only about the IT department or the legal function but rather a collaborative effort between them and other business functions. Overcoming challenges to achieve this harmony requires clear direction and support from the organisation’s governing body.

Reporting security compromises: Hitting the right notes

Even in the best-conducted symphonies, you may strike a wrong note. In the world of data protection, this corresponds to a security compromise. Reporting such a compromise responsibly under GDPR is crucial, and organisations must refer to guidance from the relevant supervisory authorities where available. Reporting breaches of personal data, not potential ones, assessing risk factors to individuals’ rights and freedoms, and excluding low-risk technical events from reporting are the key points.

Actions you can take next

Each organisation is a conductor in the grand symphony of information security management. Your organisation can secure personal data with suitable composition, synchronised instruments, clear direction, and a harmonious melody. A well-conducted symphony of information security management resonates with compliance and evokes trust among your data subjects. You can: