The Global Privacy Enforcement Network’s (GPEN) annual intelligence gathering operation has looked at how well organisations have implemented the core concepts of accountability into their own internal privacy policies and programmes. The joint study, known as the ‘GPEN Sweep’, is carried out by data protection regulators across the globe and, this year, examines how they have taken responsibility for complying with data protection laws.
While there were examples of good practice, it was found that a number of organisations had no processes in place to deal with the complaints and queries raised by data subjects, and were not equipped to handle data security incidents appropriately.
Adam Stevens, head of intelligence at the Information Commissioner’s Office (ICO), said: “The findings suggest that, while organisations contacted by the ICO and our international partners have a good understanding of the basic concept of accountability, in practice there’s significant room for improvement. It’s important that organisations have appropriate technical and organisational measures in place. This includes having clear data protection policies, taking a ‘data protection by design and default’ approach and continuing to review and monitor performance and adherence to data protection rules and regulations.”
‘GPEN Sweep’: the key results
Participating GPEN members made contact with 356 organisations in 18 countries during the ‘sweep’ exercise and have arrived at the following conclusions:
*When it comes to monitoring internal performance in relation to data protection standards, many organisations were found to fall short, with around a quarter who responded having no programmes in place to conduct self-assessments and/or internal audits
*Organisations were generally found to be quite good at giving data protection training to staff, but often failed to provide refresher training for existing staff
*The organisations that indicated they have monitoring programmes in place generally gave examples of good practice, noting that they conduct annual audits or reviews and/or regular self-assessments
*Nearly 75% of organisations across all sectors and jurisdictions had appointed an individual or team who would assume responsibility for ensuring compliance with relevant data protection rules and regulations
*Over 50% of those organisations surveyed indicated they’ve documented incident response procedures nd that they maintain up-to-date records of all data security incidents and breaches. However, a number of organisations indicated they have no processes in place to respond appropriately in the event of a data security incident
In terms of national findings, the ICO made contact with 28 organisations across various sectors in the UK and has come to the following conclusions:
*Only 67% of organisations who provided a response said that they conduct regular self-assessments or audits of internal data protection standards and practices, while only 67% indicated they maintain inventories of personal data held
*It was positive to note that 100% of organisations in the UK who provided a response indicated they felt they had someone within the organisation at a sufficiently senior level responsible for privacy governance and management
As a result of the investigation, individual GPEN members may contact organisations in their own countries to assess what remedial action they need to take in order to improve user controls over personal information.