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Data Privacy Handbook

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Data Privacy Handbook Data Privacy Handbook A starter guide to data privacy compliance 1 Contents 04 06 07 A quick introduction About this handbook Why is data privacy to data privacy important? 08 09 10 Key concepts Key principles of What is personal data privacy data? 11 12 14 What is sensitive Controllers vs. Individuals’ rights personal data? processors 15 16 When can personal Ten steps to an data be processed? effective data privacy programme 2 3 A quick introduction to data privacy There are many definitions for ‘data marketing is now forbidden under data privacy In the past year there were a series of high- In the Middle East, some GCC States have privacy’. The simplest way to think about laws but it does mean that organisations profile data breaches followed by mega-fines already adopted their own privacy laws it is that people (customers, employees, need to be transparent about what personal from regulators. This has increased awareness and other states have singalled their intent anybody!) need to know what personal data data they are capturing and how it’s going to about the importance of data privacy and to release similar legislation in the near organisations are collecting about them be used. Many organisations recognise the protection. The European Union (EU) also future. Many of the recent data privacy laws, and how they are using it. Of course, this a significant risks of cyber attacks and data introduced the “General Data Protection including local Middle East data protection simplistic way to look at the topic but it is breaches but fail to understand what else is Regulation” (GDPR), which set stricter laws, have striking similarities with the GDPR. useful to set the scene. required to safeguard what is referred to as standards for data privacy and protection This is not surprising because the GDPR the “rights and freedoms of individuals”. and further increased awareness around the radically overhauled data privacy practices Data privacy is far more than just the security importance of data protection compliance. and is now considered the gold standard in and protection of personal data. It all boils data privacy, worldwide. down to how organisations are using that personal data. Organisations need to process personal data in an ethical and legal manner. That could mean not bombarding customers with unwanted SMS marketing messages but it could also mean simply not sharing personal information with third parties without the customer’s consent. It doesn’t mean that 4 5 About this Why is data privacy important? handbook Companies that fail to protect personal data and comply with data privacy regulations aren’t just risking financial penalties. They also risk operational inefficiencies, intervention byegulators r and most importantly permanent loss of consumer trust. The data privacy landscape is complex and This toolkit reflects best practices aligned to Regulatory it continues to evolve. It presents many the requirements of the GDPR, requirements Data protection regulators may enforce Reputational challenges to organisations by creating and practices specific to the Middle mandatory audits, request access to Non-compliance with the the law uncertainty on many levels about whether, East region and PwC’s own proprietary documentation and evidence or even could result in brand damage, loss how, and when to process personal data. The frameworks. The toolkit is suitable for all mandate that an organisation stops of consumer trust, loss of employee complex implementation of the GDPR and organisations processing personal data and processing personal data. trust and customer attrition. the continuing efforts worldwide to draft local looking for a practical approach to build their data privacy regulations are having a serious data privacy programmes, be it to comply impact on organisations’ abilities to update with privacy regulations or to gain competitive and align their business practices to the ever- advantage. changing regulatory requirements. We’ve put together this Data Privacy Handbook to try to simplify the requirements and help you kick-start your data privacy compliance journey. The toolkit contains useful information and resources to help you assess your current business processes against data privacy best practices and take the necessary steps to improve them. Financial and criminal Operational Fines and, in some countries potential Most data privacy laws give people prison sentences, could be enforced more rights over their data, such as depending on the violation. the right to access their data or the You may also experience loss of right for it to be deleted. This can be a revenue and high litigation and significant operational burden if it is not remediation costs. implemented effectively. 6 7 Key concepts Key principles of data privacy Data privacy laws introduce a number of new Most data protection laws are built on a set of key principles, which establish the foundation for terms and concepts which are important everything related to data privacy and the protection of personal data. for you to familiarise yourself with, before continuing. There are seven key data privacy principles that form the fundamental conditions that organisations must follow when processing personal data. Processing personal data in line with these key principles is essential for good data protection. ‘Data processing’ or ‘Processing’ means any automated or manual operation(s) The principles are: carried out on personal data. In essence, this covers almost any relevant action word that could possibly be performed on information Lawfulness, fairness and Purpose limitation Data minimisation including collecting, recording, organising, transparency classifying, storing, modifying, amending, You should only process You must ensure you retrieving, using or revealing such data by You should always personal data for a are only processing the broadcasting, publishing, transmitting, making process personal data in a specified and lawful personal data that you available to others, integrating, blocking, fair, lawful and transparent purpose. truly need and nothing deleting or destroying. manner. more. ‘Data protection authority’ or ‘Authority’ is the national body established to be responsible for upholding the rights of individuals to the protection of their personal data through the enforcement and monitoring Accuracy Storage limitation Integrity and of compliance with the local data privacy laws. confidentiality You should ensure You must not keep personal data is kept up to personal data for longer You must implement date, and that necessary than you need it. adequate security controls A ‘Data Subject’ or ‘Individual’ is defined as measures are in place for to ensure that personal the person to whom the personal data relates. correcting and updating data is protected against inaccurate data. loss, destruction or damage. ‘Personal data’ is defined as information that relates to an identifiable person, either directly or indirectly. Refer to page 10 for further Accountability details. You must have appropriate measures and records in place to be able ‘Sensitive personal data’ is a subset of to demonstrate your personal data and is defined as information compliance. that directly or indirectly reveals a person’s race, ethnicity, political or philosophical views, religious beliefs, union affiliation, criminal record or any data related to their health or sexual life. Refer to page 5 for further details. 8 9 What is personal data? What is sensitive personal data? Personal data is any information that can identify a living person. This could be as simple Some personal data is considered sensitive, as it could cause harm to the individual if leaked or as a name or account number or could be a digital identifier such as IP address, username misused. While each data privacy law may have its own nuances, personal data is classified as or location data such as GPS coordinates. ‘sensitive’ if it relates to: Examples of personal data Racial or ethnic Political or Trade union origin religious beliefs membership • Name and surname • ID card number • Online identifiers (e.g. usernames, IP addresses) Physical or mental Sex life or sexual Criminal offences health orientation and court • CCTV footage proceedings Examples of sensitive personal data Voice recording Examples of non-personal data • An organisation’s corporate registration number Political affiliations • Mailboxes such as [email protected] Health records Biometrics It’s important to be aware that an individual can be identified either: • Directly, if you are able to identify a specific individual solely through the data you’re processing. Example: name, ID number, email address. • Indirectly, if different sets of data from different sources, when combined, could identify a specific person. Example: gender, birth date, licence plate number. It’s important to differentiate between personal data and sensitive personal data because the processing of sensitive personal data usually requires additional safeguards to be in place. 10 11 Controllers vs. processors What does it mean if I am a.. Data privacy laws draw a clear distinction between data ‘controllers’ and data ‘processors’ to recognise that not all organisations involved with the processing of personal data have the same Data controller responsibilities. You are ultimately accountable for your own compliance and the compliance of your processors. Your responsibilities include compliance with data protection principles, Controllers ‘determine the purpose
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