Workshop Privacy Impact Assessments The NOREA-PIA: design and experience

Size: px
Start display at page:

Download "Workshop Privacy Impact Assessments The NOREA-PIA: design and experience"

Transcription

1 PI.lab: Privacy in 2014 Workshop Privacy Impact Assessments The NOREA-PIA: design and experience Wolter Karssenberg RE Member of the Knowledge Group Privacy Audits NOREA (NOREA is the professional association for IT-auditors in the Netherlands) Management Consultant and Co-owner Social Force (Social Force is an advisory firm in the field of reducing household debt, improving debt collection and protecting privacy) 1

2 NOREA-PIA background: Privacy is in the spotlight Corporate Social Responsibility / Competitive Edge Resolution Franken (First Chamber / Senate) Resolution Schouw and Elissen (Second Chamber / HoR) Coalition Agreement VVD/PvdA EU General Data Protection Regulation (LIBE compromise) Growing importance of privacy risk IT-auditors are increasingly asked to execute PIA s No Dutch PIA available Guide NOREA-members to execute PIA s 2

3 EU DPR (LIBE-compromise): Recital 71a: Impact assessments are the essential core of any sustainable data protection framework and Data protection impact assessments should consequently have regard to the entire lifecycle management of personal data Recital 74a: Impact assessments can only be of help if controllers make sure that they comply with the promises originally laid down in them. Data controllers should therefore conduct periodic data protection compliance reviews demonstrating that the data processing mechanisms in place comply with assurances made in the data protection impact assessment. 3

4 EU DPR (LIBE-compromise): Article 32/33: Data Protection Impact Assessments required for operations that present specific risks, e.g.: More than 5,000 data subjects Large scale filing systems with location data, data on children or employees Profiling on which measures are based that significantly affect the data subject Article 33a: Compliance review required at least every two years after carrying out a PIA demonstrating that the processing is in compliance with the PIA (immediately when there is a change in specific risks) 4

5 NOREA-PIA objectives: Systematically detecting the risks of privacy violation To which extend In which area s Documenting privacy risk exposure Contributing to avoiding or reducing privacy risks Define required action to mitigate detected privacy risks 5

6 NOREA-PIA objectives: Preventing costly (late stage) changes Reducing monitoring and enforcement impact Improving service Improving decision making Raising privacy awareness Improving project feasibility Strengthening customer/emloyee/citizen confidence Improving communication about privacy 6

7 NOREA-PIA privacy principles (OECD): OECD Privacy Principles Collection Limitation Principle Data Quality Principle Purpose Specification Principle Use Limitation Principle Security Safeguards Principle Openness Principle Individual Participation Principle Accountability Principle 7

8 NOREA-PIA structure: 1. Introduction: background and and interests 2. Process: steps and considerations 3. Questionnaire: questions and explanations 4. Annexes: terms and abbreviations 8

9 NOREA-PIA roadmap: Determine who will perform the PIA and how this should be done Gather relevant information about the project Enter the PIA questionnaire Assess the impact and define additional measures Write the PIA report Optional: perform an (independent) evaluation of the PIA 9

10 NOREA-PIA questionnaire: The initiative / the project Project type Data Stakeholders The data lifecycle Collect Utilize Store / delete Secure 10

11 The NOREA-PIA: experience NOREA-PIA pitfalls: Client: Ready for production, let s check privacy compliance with a PIA As small a scope as possible We ve executed a PIA, so we re compliant PIA professional: A fool with a tool is still a fool If all you have is a hammer, everything looks like a nail Hype Risk! 11

12 PIA- depth The NOREA-PIA: experience NOREA-PIA pitfalls expectation management: Part-scope compliance assessment Part-scope questionnaire Full scope compliance assessment Full scope questionnaire Discuss Refuse if necessary Explain! PIA-width 12

13 The NOREA-PIA: experience NOREA-PIA pitfalls expectation management: Important part of legislation is principle based, a.o.: Proportionality principle Subsidiarity principle 13

14 The NOREA-PIA: experience NOREA-PIA pitfalls expectation management: Development phase Exploitation phase Legal Quality PIA Development phase Partial scope 14

15 The NOREA-PIA: experience NOREA-PIA is a good tool, if Adequate expectation management Adequate integral Life Cycle Data Protection Management, e.g.: PIA update management (important design changes, before go-/nogo-decisions) Privacy by Design ISO2700x on ICT security Full-scope compliance assessments Accountability mgt (continuously enable the controller to demonstrate compliance) Integral part of the organization s Risk Management Strategy Adequate expertise management Adequate stakeholder management Adequate transparancy management 15

16 The NOREA-PIA: experience NOREA-PIA is a good tool, if Adequate professional conduct management (NOREA): Rules of the profession and code of conduct Guidelines and recommendations An independent tribunal for dealing with complaints and disputes Adequate change management: 2014: planned evaluation in conjunction with the Toetsmodel PIA (government) New legislation: security breach notification law, EU DPR, etc. Specific PIA s (e.g. via annexes)? (but: you re never going to be comlete ) Small scope PIA? (but: high risk for expectation gap) 16

17 PI.lab: Privacy in 2014 Workshop Privacy Impact Assessments The NOREA-PIA: design and experience NOREA-PIA: Wolter Karssenberg RE Phone: Linkedin: 17

Our Commitment to Information Security

Our Commitment to Information Security Our Commitment to Information Security What is HIPPA? Health Insurance Portability and Accountability Act 1996 The HIPAA Privacy regulations require health care providers and organizations, as well as

More information

Information Paper for the Legislative Council Panel on Financial Affairs. Protection of Consumer Credit Data

Information Paper for the Legislative Council Panel on Financial Affairs. Protection of Consumer Credit Data LC Paper No. CB(1)691/03-04(01) Information Paper for the Legislative Council Panel on Financial Affairs Protection of Consumer Credit Data Purpose Pursuant to the request by the Panel vide the Clerk to

More information

Align Technology. Data Protection Binding Corporate Rules Processor Policy. 2014 Align Technology, Inc. All rights reserved.

Align Technology. Data Protection Binding Corporate Rules Processor Policy. 2014 Align Technology, Inc. All rights reserved. Align Technology Data Protection Binding Corporate Rules Processor Policy Confidential Contents INTRODUCTION TO THIS POLICY 3 PART I: BACKGROUND AND ACTIONS 4 PART II: PROCESSOR OBLIGATIONS 6 PART III:

More information

CLOUD COMPUTING FOR SMALL- AND MEDIUM-SIZED ENTERPRISES:

CLOUD COMPUTING FOR SMALL- AND MEDIUM-SIZED ENTERPRISES: CLOUD COMPUTING FOR SMALL- AND MEDIUM-SIZED ENTERPRISES: Privacy Responsibilities and Considerations Cloud computing is the delivery of computing services over the Internet, and it offers many potential

More information

Data Breach Notification Duty. Dr. Elisabeth Thole 31 October 2015 UIA Valencia

Data Breach Notification Duty. Dr. Elisabeth Thole 31 October 2015 UIA Valencia Data Breach Notification Duty Dr. Elisabeth Thole 31 October 2015 UIA Valencia Van Doorne 2 How is your cyber crime awareness? Either you have been data breached or you just do not know that you have been

More information

SUMMARY OF THE IMPACT ASSESSMENT

SUMMARY OF THE IMPACT ASSESSMENT EN EN EN EUROPEAN COMMISSION Brussels, 12.7.2010 SEC(2010) 846 COMMISSION STAFF WORKING DOCUMENT SUMMARY OF THE IMPACT ASSESSMENT Accompanying document to the Proposal for a DIRECTIVE OF THE EUROPEAN PARLIAMENT

More information

GOVERNANCE DEFINED. Governance is the practice of making enterprise-wide decisions regarding an organization s informational assets and artifacts

GOVERNANCE DEFINED. Governance is the practice of making enterprise-wide decisions regarding an organization s informational assets and artifacts GOVERNANCE DEFINED Governance is the practice of making enterprise-wide decisions regarding an organization s informational assets and artifacts Governance over the use of technology assets can be seen

More information

In order to achieve this goal and to address the concerns from NGOs with regards to reporting tools, we have carried out these actions:

In order to achieve this goal and to address the concerns from NGOs with regards to reporting tools, we have carried out these actions: WG1: Reporting Tools Background info The definition of reporting tools, according to the statement of purpose of the CEO Coalition to make the Internet a Better Place for Children is: robust mechanisms

More information

Self assessment tool. Using this tool

Self assessment tool. Using this tool Self assessment tool How well does your organisation comply with the 12 guiding principles of the surveillance camera code of practice? Complete this easy to use self assessment tool to find out if you

More information

Published by the National Regulatory System for Community Housing Directorate. Document Identification: 003-04-13/NRSD. Publication date: January 2014

Published by the National Regulatory System for Community Housing Directorate. Document Identification: 003-04-13/NRSD. Publication date: January 2014 Evidence guidelines Published by the National Regulatory System for Community Housing Directorate. Document Identification: 003-04-13/NRSD Publication date: January 2014 Supported by the Commonwealth Government

More information

COCIR contribution to the public consultation on Personal Data Protection in the EU 1

COCIR contribution to the public consultation on Personal Data Protection in the EU 1 COCIR contribution to the public consultation on Personal Data Protection in the EU 1 European Coordination Committee of the Radiological, Electromedical and Healthcare IT Industry Bd. A. Reyers 80, 1030

More information

Iowa Student Loan Online Privacy Statement

Iowa Student Loan Online Privacy Statement Iowa Student Loan Online Privacy Statement Revision date: Jan.6, 2014 Iowa Student Loan Liquidity Corporation ("Iowa Student Loan") understands that you are concerned about the privacy and security of

More information

Daltrak Building Services Pty Ltd ABN: 44 069 781 933. Privacy Policy Manual

Daltrak Building Services Pty Ltd ABN: 44 069 781 933. Privacy Policy Manual Daltrak Building Services Pty Ltd ABN: 44 069 781 933 Privacy Policy Manual Table Of Contents 1. Introduction Page 2 2. Australian Privacy Principles (APP s) Page 3 3. Kinds Of Personal Information That

More information

Christine M. Frye, CIPP/US, CIPM, Chief Privacy Officer, Bank of America

Christine M. Frye, CIPP/US, CIPM, Chief Privacy Officer, Bank of America Christine M. Frye, CIPP/US, CIPM, Chief Privacy Officer, Bank of America Dana Simberkoff, JD, CIPP/US, Vice President, Risk Management and Compliance, AvePoint The Landscape Prevention and Response Planning

More information

IAPP Global Privacy Summit Protecting Privacy Under the Cybersecurity Microscope

IAPP Global Privacy Summit Protecting Privacy Under the Cybersecurity Microscope IAPP Global Privacy Summit Protecting Privacy Under the Cybersecurity Microscope March 6, 2014 Victoria King UPS (404) 828-6550 vking@ups.com Lisa J. Sotto Hunton & Williams LLP (212) 309-1223 lsotto@hunton.com

More information

PCI Solution for Retail: Addressing Compliance and Security Best Practices

PCI Solution for Retail: Addressing Compliance and Security Best Practices PCI Solution for Retail: Addressing Compliance and Security Best Practices Executive Summary The Payment Card Industry (PCI) Data Security Standard has been revised to address an evolving risk environment

More information

Definitions: Policy: Duties and Responsibilities: The Privacy Officer will have the following responsibilities and duties:

Definitions: Policy: Duties and Responsibilities: The Privacy Officer will have the following responsibilities and duties: PRIVACY 1.0 FACILITY PRIVACY OFFICER Scope: Purpose: All subsidiaries of Universal Health Services, Inc., including facilities and UHS of Delaware Inc. (collectively, UHS ), including UHS covered entities

More information

TRANSPOSITION NOTE. Directive 2013/11/EU on alternative dispute resolution for consumer disputes

TRANSPOSITION NOTE. Directive 2013/11/EU on alternative dispute resolution for consumer disputes TRANSPOSITION NOTE Directive 2013/11/EU on alternative dispute resolution for consumer disputes 1. This note describes the implementation in the United Kingdom of parts of the Directive 2013/11/EU of the

More information

Data Protection Act. Conducting privacy impact assessments code of practice

Data Protection Act. Conducting privacy impact assessments code of practice Data Protection Act Conducting privacy impact assessments code of practice 1 Conducting privacy impact assessments code of practice Data Protection Act Contents Information Commissioner s foreword... 3

More information

Credit Union Code for the Protection of Personal Information

Credit Union Code for the Protection of Personal Information Introduction Canada is part of a global economy based on the creation, processing, and exchange of information. The technology underlying the information economy provides a number of benefits that improve

More information

OVERVIEW. stakeholder engagement mechanisms and WP29 consultation mechanisms respectively.

OVERVIEW. stakeholder engagement mechanisms and WP29 consultation mechanisms respectively. Joint work between experts from the Article 29 Working Party and from APEC Economies, on a referential for requirements for Binding Corporate Rules submitted to national Data Protection Authorities in

More information

Information Security Program CHARTER

Information Security Program CHARTER State of Louisiana Information Security Program CHARTER Date Published: 12, 09, 2015 Contents Executive Sponsors... 3 Program Owner... 3 Introduction... 4 Statewide Information Security Strategy... 4 Information

More information

La Trobe University is committed to maintaining a comprehensive and effective Compliance Framework.

La Trobe University is committed to maintaining a comprehensive and effective Compliance Framework. La Trobe University Compliance Framework Introduction The Compliance Framework documents the system and Compliance Process through which La Trobe University can monitor, review and comply with its legislative

More information

Top Five Privacy and Data Security Issues for Nonprofit Organizations

Top Five Privacy and Data Security Issues for Nonprofit Organizations Top Five Privacy and Data Security Issues for Nonprofit Organizations Julia K. Tama, Esq. Jeffrey S. Tenenbaum, Esq. Association of Corporate Counsel Nonprofit Organizations Committee Legal Quick Hit MAY

More information

Accountability: Data Governance for the Evolving Digital Marketplace 1

Accountability: Data Governance for the Evolving Digital Marketplace 1 Accountability: Data Governance for the Evolving Digital Marketplace 1 1 For the past three years, the Centre for Information Policy Leadership at Hunton & Williams LLP has served as secretariat for the

More information

Governance and Management of Information Security

Governance and Management of Information Security Governance and Management of Information Security Øivind Høiem, CISA CRISC Senior Advisor Information Security UNINETT, the Norwegian NREN About Øivind Senior Adviser at the HE sector secretary for information

More information

CFPB Readiness Series: Compliant Vendor Management Overview

CFPB Readiness Series: Compliant Vendor Management Overview CFPB Readiness Series: Compliant Vendor Management Overview Legal Disclaimer This information is not intended to be legal advice and may not be used as legal advice. Legal advice must be tailored to the

More information

Digital Asset Manager, Digital Curator. Cultural Informatics, Cultural/ Art ICT Manager

Digital Asset Manager, Digital Curator. Cultural Informatics, Cultural/ Art ICT Manager Role title Digital Cultural Asset Manager Also known as Relevant professions Summary statement Mission Digital Asset Manager, Digital Curator Cultural Informatics, Cultural/ Art ICT Manager Deals with

More information

The Legal Pitfalls of Failing to Develop Secure Cloud Services

The Legal Pitfalls of Failing to Develop Secure Cloud Services SESSION ID: CSV-R03 The Legal Pitfalls of Failing to Develop Secure Cloud Services Cristin Goodwin Senior Attorney, Trustworthy Computing & Regulatory Affairs Microsoft Corporation Edward McNicholas Global

More information

The Commission proposal is in the left column, our suggestions in the right column. Recital 46. deleted

The Commission proposal is in the left column, our suggestions in the right column. Recital 46. deleted EDRi amendments on the proposed Regulation laying down measures concerning the European single market for electronic communications and to achieve a Connected Continent, and amending Directives 2002/20/EC,

More information

Privacy Impact Assessment

Privacy Impact Assessment AUGUST 16, 2013 Privacy Impact Assessment CIVIL PENALTY FUND AND BUREAU-ADMINISTERED REDRESS PROGRAM Contact Point: Claire Stapleton Chief Privacy Officer 1700 G Street, NW Washington, DC 20552 202-435-7220

More information

Vendor Management Challenge Doing More with Less

Vendor Management Challenge Doing More with Less Vendor Management Challenge Doing More with Less Megan Hertzler Assistant General Counsel Director of Data Privacy Xcel Energy Boris Segalis Partner InfoLawGroup LLP Session ID: GRC-402 Insert presenter

More information

LEGAL SERVICES DIRECTIONS 2005 - COMPLIANCE FRAMEWORK

LEGAL SERVICES DIRECTIONS 2005 - COMPLIANCE FRAMEWORK LEGAL SERVICES DIRECTIONS 2005 - COMPLIANCE FRAMEWORK Purpose of the Compliance Framework 1. The purpose of this Framework is to set out: the approach of the Office of Legal Services Coordination (OLSC)

More information

BUSINESS ASSOCIATE PRIVACY AND SECURITY ADDENDUM RECITALS

BUSINESS ASSOCIATE PRIVACY AND SECURITY ADDENDUM RECITALS BUSINESS ASSOCIATE PRIVACY AND SECURITY ADDENDUM This Business Associate Addendum ( Addendum ), effective, 20 ( Effective Date ), is entered into by and between University of Southern California, ( University

More information

AIRBUS GROUP BINDING CORPORATE RULES

AIRBUS GROUP BINDING CORPORATE RULES 1 AIRBUS GROUP BINDING CORPORATE RULES 2 Introduction The Binding Corporate Rules (hereinafter BCRs ) of the Airbus Group finalize the Airbus Group s provisions on the protection of Personal Data. These

More information

INSURANCE BROKERS CODE OF PRACTICE

INSURANCE BROKERS CODE OF PRACTICE INSURANCE BROKERS CODE OF PRACTICE INSURANCE BROKERS CODE OF PRACTICE OVERVIEW 4-5 IMPORTANT BACKGROUND INFORMATION What does the Code do for you? (Code Objectives) How to navigate the Code How up to date

More information

Supervisory Policy Manual

Supervisory Policy Manual This module should be read in conjunction with the Introduction and with the Glossary, which contains an explanation of abbreviations and other terms used in this Manual. If reading on-line, click on blue

More information

EU Cybersecurity Policy & Legislation ENISA s Contribution

EU Cybersecurity Policy & Legislation ENISA s Contribution EU Cybersecurity Policy & Legislation ENISA s Contribution Steve Purser Head of Core Operations Oslo 26 May 2015 European Union Agency for Network and Information Security Agenda 01 Introduction to ENISA

More information

Tax risk management strategy

Tax risk management strategy Vodafone Group Plc has a tax strategy focused on the following 6 key areas: Integrity in compliance and reporting Enhancing shareholder value Business partnering Influencing tax policy Developing our people

More information

Privacy, Records Management and Information Security at the University of Victoria

Privacy, Records Management and Information Security at the University of Victoria Privacy, Records Management and Information Security at the University of Victoria A YEAR IN REVIEW 2015 Chief Information Officer, University Systems Chief Privacy Officer, Office of the University Secretary

More information

HIPAA Privacy Rule Policies

HIPAA Privacy Rule Policies DRAFT - Policies and Procedures PRIVACY OFFICE ASSIGNMENT AND RESPONSIBILITIES APPROVED BY: SUPERCEDES POLICY: Policy #1 ADOPTED: REVISED: REVIEWED: Purpose This policy is designed to assure the establishment

More information

Sample Business Associate Agreement (4. Other Bus. Assoc., Version 6-06-05)

Sample Business Associate Agreement (4. Other Bus. Assoc., Version 6-06-05) Sample Business Associate Agreement (4. Other Bus. Assoc., Version 6-06-05) This Business Associate Agreement (the Agreement ) is entered into as of, 20, (the Effective Date ) by and between, (the Covered

More information

A Best Practice Guide

A Best Practice Guide A Best Practice Guide Contents Introduction [2] The Benefits of Implementing a Privacy Management Programme [3] Developing a Comprehensive Privacy Management Programme [3] Part A Baseline Fundamentals

More information

Code of Conduct for Mobile Money Providers

Code of Conduct for Mobile Money Providers Code of Conduct for Mobile Money Providers SOUNDNESS OF SERVICES FAIR TREATMENT OF CUSTOMERS SECURITY OF THE MOBILE NETWORK AND CHANNEL VERSION 2 - OCTOBER 2015 Introduction This Code of Conduct identifies

More information

Ethical Trading Initiative Management Benchmarks

Ethical Trading Initiative Management Benchmarks Ethical Trading Initiative Management Benchmarks The Management Benchmarks are the means by which ETI (a) sets out its expectations of members and (b) measures members progress in applying the ETI Base

More information

Align Technology. Data Protection Binding Corporate Rules Controller Policy. 2014 Align Technology, Inc. All rights reserved.

Align Technology. Data Protection Binding Corporate Rules Controller Policy. 2014 Align Technology, Inc. All rights reserved. Align Technology Data Protection Binding Corporate Rules Controller Policy Contents INTRODUCTION 3 PART I: BACKGROUND AND ACTIONS 4 PART II: CONTROLLER OBLIGATIONS 6 PART III: APPENDICES 13 2 P a g e INTRODUCTION

More information

Template for Automatic Number Plate Recognition (ANPR) Infrastructure Development Privacy Impact Assessment

Template for Automatic Number Plate Recognition (ANPR) Infrastructure Development Privacy Impact Assessment Template for Automatic Number Plate Recognition (ANPR) Infrastructure Development Privacy Impact Assessment This template is provided to support the police service and other law enforcement agencies (LEA)

More information

APB ETHICAL STANDARD 5 NON-AUDIT SERVICES PROVIDED TO AUDIT CLIENTS

APB ETHICAL STANDARD 5 NON-AUDIT SERVICES PROVIDED TO AUDIT CLIENTS APB ETHICAL STANDARD 5 NON-AUDIT SERVICES PROVIDED TO AUDIT CLIENTS (Re-issued December 2004) Contents paragraph Introduction 1-4 General approach to non-audit services 5-38 Identification and assessment

More information

COMMENTS OF THE ELECTRONIC PRIVACY INFORMATION CENTER THE FEDERAL TRADE COMMISSION. In the Matter of Myspace, LLC. FTC File No. 102 3058.

COMMENTS OF THE ELECTRONIC PRIVACY INFORMATION CENTER THE FEDERAL TRADE COMMISSION. In the Matter of Myspace, LLC. FTC File No. 102 3058. COMMENTS OF THE ELECTRONIC PRIVACY INFORMATION CENTER to THE FEDERAL TRADE COMMISSION In the Matter of Myspace, LLC FTC File No. 102 3058 June 8, 2012 By notice published on May 14, 2012, the Federal Trade

More information

Ombudsman Services response to the TSI consultation. Consumer Code Approval scheme

Ombudsman Services response to the TSI consultation. Consumer Code Approval scheme Ombudsman Services response to the TSI consultation Consumer Code Approval scheme Response of the Ombudsman Service Ltd (Ombudsman Services) to the TSI consultation: Consumer Code Approval Scheme 1 Summary

More information

Information Security Management Systems

Information Security Management Systems Information Security Management Systems Øivind Høiem CISA, CRISC, ISO27001 Lead Implementer Senior Advisor Information Security UNINETT, the Norwegian NREN About Øivind Senior Adviser at the HE sector

More information

Cloud Adoption Practices & Priorities Survey Report

Cloud Adoption Practices & Priorities Survey Report Cloud Adoption Practices & Priorities Survey Report January 2015 2015 Cloud Security Alliance All Rights Reserved All rights reserved. You may download, store, display on your computer, view, print, and

More information

Privacy in the Cloud A Microsoft Perspective

Privacy in the Cloud A Microsoft Perspective A Microsoft Perspective November 2010 The information contained in this document represents the current view of Microsoft Corp. on the issues discussed as of the date of publication. Because Microsoft

More information

REGULATORY CHANGES DEMAND AN ENTERPRISE-WIDE APPROACH TO DISCLOSURE MANAGEMENT OF PHI

REGULATORY CHANGES DEMAND AN ENTERPRISE-WIDE APPROACH TO DISCLOSURE MANAGEMENT OF PHI REGULATORY CHANGES DEMAND AN ENTERPRISE-WIDE APPROACH TO DISCLOSURE MANAGEMENT OF PHI Healthcare Organizations Can Adopt Enterprise-Wide Disclosure Management Systems To Standardize Disclosure Processes,

More information

Establishing a Business Development Roadmap

Establishing a Business Development Roadmap Establishing a Business Development Roadmap Designs Designs That That Work. Work. Before Have You Ever Experienced Something Similar To This? Proposal Process RFP Release Identify Identify Gaps Start Proposal

More information

Planning for Success: Privacy Impact Assessment Guide

Planning for Success: Privacy Impact Assessment Guide Planning for Success: Privacy Impact Assessment Guide Acknowledgement This guide is partially based on the Privacy Impact Assessment Guides and Tools developed by the Ministry of Government and Consumer

More information

Stakeholder Engagement Initiative: Customer Relationship Management

Stakeholder Engagement Initiative: Customer Relationship Management for the Stakeholder Engagement Initiative: December 10, 2009 Contact Point Christine Campigotto Private Sector Office Policy 202-612-1623 Reviewing Official Mary Ellen Callahan Chief Privacy Officer Department

More information

E-PRIVACY DIRECTIVE: Personal Data Breach Notification

E-PRIVACY DIRECTIVE: Personal Data Breach Notification E-PRIVACY DIRECTIVE: Personal Data Breach Notification PUBLIC CONSULTATION BEUC Response Contact: Kostas Rossoglou digital@beuc.eu Ref.: X/2011/092-13/09/11 EC register for interest representatives: identification

More information

STFC Monitoring and Interception policy for Information & Communications Technology Systems and Services

STFC Monitoring and Interception policy for Information & Communications Technology Systems and Services STFC Monitoring and Interception policy for Information & Communications Technology Systems and Services Issue 1.0 (Effective 27 June 2012) This document contains a copy of the STFC policy statements outlining

More information

Independence Audit and Review Engagements. Independence Other Assurance Engagements

Independence Audit and Review Engagements. Independence Other Assurance Engagements International Ethics Standards Board for Accountants Exposure Draft December 2006 Comments are requested by April 30, 2007 Section 290 of the Code of Ethics Independence Audit and Review Engagements Section

More information

Information Governance Strategy :

Information Governance Strategy : Item 11 Strategy Strategy : Date Issued: Date To Be Reviewed: VOY xx Annually 1 Policy Title: Strategy Supersedes: All previous Strategies 18/12/13: Initial draft Description of Amendments 19/12/13: Update

More information

ADMINISTRATIVE POLICY # 32 8 2 (2014) Information Security Roles and Responsibilities

ADMINISTRATIVE POLICY # 32 8 2 (2014) Information Security Roles and Responsibilities Policy Title: Information Security Roles Policy Type: Administrative Policy Number: ADMINISTRATIVE POLICY # 32 8 2 (2014) Information Security Roles Approval Date: 05/28/2014 Revised Responsible Office:

More information

NEW PERSPECTIVES. Professional Fee Coding Audit: The Basics. Learn how to do these invaluable audits page 16

NEW PERSPECTIVES. Professional Fee Coding Audit: The Basics. Learn how to do these invaluable audits page 16 NEW PERSPECTIVES on Healthcare Risk Management, Control and Governance www.ahia.org Journal of the Association of Heathcare Internal Auditors Vol. 32, No. 3, Fall, 2013 Professional Fee Coding Audit: The

More information

HIPAA PRIVACY FOR EMPLOYERS A Comprehensive Introduction. HIPAA Privacy Regulations-General

HIPAA PRIVACY FOR EMPLOYERS A Comprehensive Introduction. HIPAA Privacy Regulations-General HIPAA PRIVACY FOR EMPLOYERS A Comprehensive Introduction HIPAA Privacy Regulations-General The final HIPAA Privacy regulation was released on December 20, 2000 and was effective for compliance on April

More information

A Privacy Officer s Guide to Providing Enterprise De-Identification Services. Phase I

A Privacy Officer s Guide to Providing Enterprise De-Identification Services. Phase I IT Management Advisory A Privacy Officer s Guide to Providing Enterprise De-Identification Services Ki Consulting has helped several large healthcare organizations to establish de-identification services

More information

Authorisation Requirements and Standards for Debt Management Firms

Authorisation Requirements and Standards for Debt Management Firms 2013 Authorisation Requirements and Standards for Debt Management Firms 2 Contents Authorisation Requirements and Standards for Debt Management Firms Contents Chapter Part A: Authorisation Requirements

More information

TECHNICAL SPECIFICATION: LEGISLATION EXECUTING CLOUD SERVICES

TECHNICAL SPECIFICATION: LEGISLATION EXECUTING CLOUD SERVICES REALIZATION OF A RESEARCH AND DEVELOPMENT PROJECT (PRE-COMMERCIAL PROCUREMENT) ON CLOUD FOR EUROPE TECHNICAL SPECIFICATION: LEGISLATION EXECUTING CLOUD SERVICES ANNEX IV (D) TO THE CONTRACT NOTICE TENDER

More information

Cisco Security Optimization Service

Cisco Security Optimization Service Cisco Security Optimization Service Proactively strengthen your network to better respond to evolving security threats and planned and unplanned events. Service Overview Optimize Your Network for Borderless

More information

4-column document Net neutrality provisions (including recitals)

4-column document Net neutrality provisions (including recitals) 4-column document Net neutrality provisions (including recitals) [Text for technical discussions. It does not express any position of the Commission or its services] Proposal for a REGULATION OF THE EUROPEAN

More information

Privacy & Security Matters: Protecting Personal Data. Privacy & Security Project

Privacy & Security Matters: Protecting Personal Data. Privacy & Security Project Privacy & Security Matters: Protecting Personal Data Privacy & Security Project HIPAA: What it is Health Insurance Portability and Accountability Act of 1996 Also known as Kennedy-Kassebaum Act Legislation

More information

Cloud Security Trust Cisco to Protect Your Data

Cloud Security Trust Cisco to Protect Your Data Trust Cisco to Protect Your Data As cloud adoption accelerates, organizations are increasingly placing their trust in third-party cloud service providers (CSPs). But can you fully trust your most sensitive

More information

AUDIT COMMITTEE BEST PRACTICES CHECKLIST

AUDIT COMMITTEE BEST PRACTICES CHECKLIST AUDIT COMMITTEE BEST PRACTICES CHECKLIST General 1. Members have the appropriate predefined qualifications to meet the objectives of the audit committee s charter, including appropriate financial literacy.

More information

Comments of the EDPS in response to the public consultation on

Comments of the EDPS in response to the public consultation on Comments of the EDPS in response to the public consultation on the planned guidelines on recommended standard licences, datasets and charging for the reuse of public sector information initiated by the

More information

Human Services Quality Framework. User Guide

Human Services Quality Framework. User Guide Human Services Quality Framework User Guide Purpose The purpose of the user guide is to assist in interpreting and applying the Human Services Quality Standards and associated indicators across all service

More information

INFORMATION GOVERNANCE OPERATING POLICY & FRAMEWORK

INFORMATION GOVERNANCE OPERATING POLICY & FRAMEWORK INFORMATION GOVERNANCE OPERATING POLICY & FRAMEWORK Log / Control Sheet Responsible Officer: Chief Finance Officer Clinical Lead: Dr J Parker, Caldicott Guardian Author: Associate IG Specialist, Yorkshire

More information

INSURANCE BROKERS CODE OF PRACTICE

INSURANCE BROKERS CODE OF PRACTICE INSURANCE BROKERS CODE OF PRACTICE BUILDING PROFESSIONAL COMPETENCE AND CONSUMER CONFIDENCE The insurance broking profession is about helping you to navigate the unavoidable complexities of insurance products

More information

LEEDS BECKETT UNIVERSITY. Information Security Policy. 1.0 Introduction

LEEDS BECKETT UNIVERSITY. Information Security Policy. 1.0 Introduction LEEDS BECKETT UNIVERSITY Information Security Policy 1.0 Introduction 1.1 Information in all of its forms is crucial to the effective functioning and good governance of our University. We are committed

More information

Privacy and Electronic Communications Regulations

Privacy and Electronic Communications Regulations ICO lo Notification of PECR security breaches Privacy and Electronic Communications Regulations Contents Introduction... 2 Overview... 2 Relevant security breaches... 3 What is a service provider?... 3

More information

DHS Data Privacy & Integrity Advisory Committee 07 May 2007. Comments of the. DHS Data Privacy & Integrity Advisory Committee

DHS Data Privacy & Integrity Advisory Committee 07 May 2007. Comments of the. DHS Data Privacy & Integrity Advisory Committee DHS Data Privacy & Integrity Advisory Committee 07 May 2007 Comments of the DHS Data Privacy & Integrity Advisory Committee Regarding the Notice of Propose Rulemaking For Implementation of the REAL ID

More information

005ASubmission to the Serious Data Breach Notification Consultation

005ASubmission to the Serious Data Breach Notification Consultation 005ASubmission to the Serious Data Breach Notification Consultation (Consultation closes 4 March 2016 please send electronic submissions to privacy.consultation@ag.gov.au) Your details Name/organisation

More information

Explanation where the company has partially applied or not applied King III principles

Explanation where the company has partially applied or not applied King III principles King Code of Corporate Governance for South Africa, 2009 (King III) checklist The Board of Directors (the Board) of Famous Brands Limited (Famous Brands or the company) is fully committed to business integrity,

More information

7.08.2 Privacy Rules for Customer, Supplier and Business Partner Data. Directive 7.08 Protection of Personal Data

7.08.2 Privacy Rules for Customer, Supplier and Business Partner Data. Directive 7.08 Protection of Personal Data Akzo Nobel N.V. Executive Committee Rules 7.08.2 Privacy Rules for Customer, Supplier and Business Partner Data Source Directive Content Owner Directive 7.08 Protection of Personal Data AkzoNobel Legal

More information

Sustainable Compliance: A System for Ongoing Audit Readiness

Sustainable Compliance: A System for Ongoing Audit Readiness View the Replay on YouTube Sustainable Compliance: A System for Ongoing Audit Readiness FairWarning Executive Webinar Series November 14, 2013 Agenda Sustainable Compliance at St. Charles Health System

More information

AlixPartners, LLP. General Data Protection Statement

AlixPartners, LLP. General Data Protection Statement AlixPartners, LLP General Data Protection Statement GENERAL DATA PROTECTION STATEMENT 1. INTRODUCTION 1.1 AlixPartners, LLP ( AlixPartners ) is committed to fulfilling its obligations under the data protection

More information

DASSAULT SYSTEMES GROUP HUMAN RESOURCES DATA PRIVACY POLICY

DASSAULT SYSTEMES GROUP HUMAN RESOURCES DATA PRIVACY POLICY DASSAULT SYSTEMES GROUP HUMAN RESOURCES DATA PRIVACY POLICY The following provisions make up Dassault Systèmes Group HR Data Privacy Policy (the Policy ). This Policy applies to our employees, applicants

More information

ICC RESOURCE GUIDE FOR SELF-REGULATION OF ONLINE BEHAVIOURAL ADVERTISING (OBA)

ICC RESOURCE GUIDE FOR SELF-REGULATION OF ONLINE BEHAVIOURAL ADVERTISING (OBA) ICC RESOURCE GUIDE FOR SELF-REGULATION OF ONLINE BEHAVIOURAL ADVERTISING (OBA) Highlights Explanation of global framework available for OBA self-regulation Checklist from existing OBA self-regulatory mechanisms

More information

Acquia Comments on EU Recommendations for Data Processing in the Cloud

Acquia Comments on EU Recommendations for Data Processing in the Cloud Acquia Comments on EU Recommendations for Data Processing in the Cloud Executive Summary On July 1, 2012, European Union (EU) data protection regulators provided guidelines for service providers processing

More information

Legislative Proposals for the Maryland Commission on Cyber Security Innovation and Excellence

Legislative Proposals for the Maryland Commission on Cyber Security Innovation and Excellence Legislative Proposals for the Maryland Commission on Cyber Security Innovation and Excellence December 6, 2012 Michael Greenberger Professor of Law Founder and Director, CHHS Legislative Proposals Maryland

More information

HIPAA Omnibus Rule Practice Impact. Kristen Heffernan MicroMD Director of Prod Mgt and Marketing

HIPAA Omnibus Rule Practice Impact. Kristen Heffernan MicroMD Director of Prod Mgt and Marketing HIPAA Omnibus Rule Practice Impact Kristen Heffernan MicroMD Director of Prod Mgt and Marketing 1 HIPAA Omnibus Rule Agenda History of the Rule HIPAA Stats Rule Overview Use of Personal Health Information

More information

REGULATIONS FOR THE SECURITY OF INTERNET BANKING

REGULATIONS FOR THE SECURITY OF INTERNET BANKING REGULATIONS FOR THE SECURITY OF INTERNET BANKING PAYMENT SYSTEMS DEPARTMENT STATE BANK OF PAKISTAN Table of Contents PREFACE... 3 DEFINITIONS... 4 1. SCOPE OF THE REGULATIONS... 6 2. INTERNET BANKING SECURITY

More information

RISK-BASED PLANNING FOR AUDITS OF OFFICIAL CONTROL SYSTEMS

RISK-BASED PLANNING FOR AUDITS OF OFFICIAL CONTROL SYSTEMS National Audit Systems Network RISK-BASED PLANNING FOR AUDITS OF OFFICIAL CONTROL SYSTEMS The network of national audit experts have produced this non-binding reference document based on agreed good practices

More information

Debt Recovery Policy. Version: 1.1. Date updated: Adopted 2 December 2014. Responsible Department: Finance. Related policies: Nil

Debt Recovery Policy. Version: 1.1. Date updated: Adopted 2 December 2014. Responsible Department: Finance. Related policies: Nil Debt Recovery Policy Version: 1.1 Date updated: Adopted 2 December 2014 Responsible Department: Finance Related policies: Nil 1. Purpose The purpose of Council s Debt Recovery Policy is to ensure and support

More information

European Commission Per email: CNECT-H4@ec.europa.eu

European Commission Per email: CNECT-H4@ec.europa.eu Post Bits of Freedom Bank 55 47 06 512 M +31(0)646282693 Postbus 10746 KvK 34 12 12 86 E simone.halink@bof.nl 1001 ES Amsterdam W https://www.bof.nl European Commission Per email: CNECT-H4@ec.europa.eu

More information

TG 47-01. TRANSITIONAL GUIDELINES FOR ISO/IEC 17021-1:2015, ISO 9001:2015 and ISO 14001:2015 CERTIFICATION BODIES

TG 47-01. TRANSITIONAL GUIDELINES FOR ISO/IEC 17021-1:2015, ISO 9001:2015 and ISO 14001:2015 CERTIFICATION BODIES TRANSITIONAL GUIDELINES FOR ISO/IEC 17021-1:2015, ISO 9001:2015 and ISO 14001:2015 CERTIFICATION BODIES Approved By: Senior Manager: Mpho Phaloane Created By: Field Manager: John Ndalamo Date of Approval:

More information

Terms of Business for Registered Support Providers

Terms of Business for Registered Support Providers Terms of Business for Registered Support Providers The National Disability Insurance Scheme Act 2013 provides for the making of Rules and requirements for registered providers of support. The Rule National

More information

INFORMATION GOVERNANCE AND SECURITY 1 POLICY DRAFTED BY: INFORMATION GOVERNANCE LEAD 2 ACCOUNTABLE DIRECTOR: SENIOR INFORMATION RISK OWNER

INFORMATION GOVERNANCE AND SECURITY 1 POLICY DRAFTED BY: INFORMATION GOVERNANCE LEAD 2 ACCOUNTABLE DIRECTOR: SENIOR INFORMATION RISK OWNER INFORMATION GOVERNANCE AND SECURITY 1 POLICY DRAFTED BY: INFORMATION GOVERNANCE LEAD 2 ACCOUNTABLE DIRECTOR: SENIOR INFORMATION RISK OWNER 3 APPLIES TO: ALL STAFF 4 COMMITTEE & DATE APPROVED: AUDIT COMMITTEE

More information

Listing and Admission to Trading Rules for. Short Term Paper. Release 2

Listing and Admission to Trading Rules for. Short Term Paper. Release 2 Listing and Admission to Trading Rules for Short Term Paper Release 2 14 April 2014 Scope These Listing and Admission to Trading Rules ( Rules ) relate to the Listing and admission to trading on the Main

More information

Common position of national authorities within the CPC Network

Common position of national authorities within the CPC Network Common position of national authorities within the CPC Network Assessment of proposals made by Apple, Google and relevant trade associations regarding in-app purchases in online games By letter dated 9

More information

Information Security for Managers

Information Security for Managers Fiscal Year 2015 Information Security for Managers Introduction Information Security Overview Enterprise Performance Life Cycle Enterprise Performance Life Cycle and the Risk Management Framework Categorize

More information