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            47
          
        
        
          
            VOX POP
          
        
        
          PITR:
        
        
          
            One of the requirements
          
        
        
          
            of the new legislation is to put
          
        
        
          
            procedures in place to detect,
          
        
        
          
            report and investigate a personal
          
        
        
          
            data breach. How are you
          
        
        
          
            managing this?
          
        
        
          
            Colin Griffin:
          
        
        
          “We have developed a
        
        
          set of clear internal policies and lines of
        
        
          responsibility. Robust breach detection
        
        
          investigation and reporting procedures
        
        
          are already in place, which are all in line
        
        
          with ISO: 27001 standards and managed
        
        
          by Stephen. GDPR is not simply a ‘tick-
        
        
          box’ exercise – organisations need to
        
        
          proactively monitor compliance and be
        
        
          alert to data breaches.”
        
        
          
            Matt Goodall:
          
        
        
          “The guidelines suggest
        
        
          that the easiest way to limit the potential
        
        
          for data breaches is to review, control and
        
        
          limit access to the data in the first place. As
        
        
          the fines for a breach are significant and
        
        
          can be 2% of your annual turnover, it is
        
        
          essential that you have your systems up to
        
        
          date and everyone is aware of how to use
        
        
          them. We are also reviewing how we store
        
        
          data relating to customers; the traceability
        
        
          of actions with such documents; and
        
        
          access to those systems.
        
        
          “My advice would be: ‘Don’t leave it
        
        
          too late, there is lots to comply with’.”
        
        
          
            Mark Smyth:
          
        
        
          “We are currently working
        
        
          through a check-list and process for
        
        
          identifying each business area and data,
        
        
          categorising the data, creating an audit
        
        
          and reporting process, and evaluating and
        
        
          prioritising the risks.
        
        
          “This will be introduced as a
        
        
          measurements and management process
        
        
          within our organisation come May 2018.
        
        
          We see this as a constantly evolving and
        
        
          continuous process and infrastructure
        
        
          improvement.”
        
        
          
            Melissa Odawa:
          
        
        
          “Some countries, like
        
        
          the Netherlands, already have legislation
        
        
          in place for reporting data breaches.
        
        
          Therefore, Kyocera already has a process
        
        
          for this. Managing data incidents is in
        
        
          scope of the Kyocera GDPR project.”
        
        
          
            Graham Herrington:
          
        
        
          “It ultimately
        
        
          means preparing for a breach, then working
        
        
          back from that point to ensure all ground
        
        
          is covered. For example, one company has
        
        
          prepared a mail merge document that can
        
        
          be initiated if a major breach is detected,
        
        
          ensuring the client receives notification
        
        
          within 30 minutes of it being detected.
        
        
          “As part of the documentation
        
        
          process, it’s vital to include a clear breach
        
        
          procedure that is monitored, checked
        
        
          and maintained. All data flows are tested
        
        
          against this and form part of the overall
        
        
          GDPR project folder.”
        
        
        
        
        
        
        
          
            Guidelines
          
        
        
          
            suggest
          
        
        
          
            that the
          
        
        
          
            easiest way
          
        
        
          
            to limit the
          
        
        
          
            potential
          
        
        
          
            for data
          
        
        
          
            breaches is
          
        
        
          
            to review,
          
        
        
          
            control and
          
        
        
          
            limit access
          
        
        
          
            to the data
          
        
        
          
            in the first
          
        
        
          
            place
          
        
        
          Graham Herrington,
        
        
          Managing Director,
        
        
          Managed Print Partners