Many companies have a website and a customer database. It is now essential that those of us who rely on consent to hold this data have the express permission of the individual concerned.
Personally Identifiable Information (PII) includes business email addresses as they identify specific individuals.
To meet our obligations we need to have a clear opt in policy on our website and a database that we can use to audit access. Can you do these things today? If not, please contact Insperitas so that we can help.
Article 32 of GDPR clearly indicates a need to prove security of processing.
Please see the excerpt below taken at Feb 23rd 2018 12.25 UTC from:
Article 32
Security of processing
1. Taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, the controller and the processor shall implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk, including inter alia as appropriate:
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(a) |
the pseudonymisation and encryption of personal data; |
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(b) |
the ability to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services; |
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(c) |
the ability to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident; |
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(d) |
a process for regularly testing, assessing and evaluating the effectiveness of technical and organisational measures for ensuring the security of the processing. |
2. In assessing the appropriate level of security account shall be taken in particular of the risks that are presented by processing, in particular from accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to personal data transmitted, stored or otherwise processed.
3. Adherence to an approved code of conduct as referred to in Article 40 or an approved certification mechanism as referred to in Article 42 may be used as an element by which to demonstrate compliance with the requirements set out in paragraph 1 of this Article.
4. The controller and processor shall take steps to ensure that any natural person acting under the authority of the controller or the processor who has access to personal data does not process them except on instructions from the controller, unless he or she is required to do so by Union or Member State law.