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I work for a business that designs, builds and supports learning management systems for corporate organisations. I also had the task of coordinating our GDPR re
by linker3000 8y ago
I work for a business that designs, builds and supports learning management systems for corporate organisations. I also had the task of coordinating our GDPR readiness activities.
As we are a 'processor' for our clients, we reviewed and updated some of our existing infosec policies and procedures, and produced a very detailed set of 'GDPR' docs to satisfy customers asking for evidence of our compliance efforts, and to provide data mappings, impact and risk assessments etc. We already had most of this done internally anyway so we just needed to 'prettify' it and change the language/terms in our 'Electronic Information Security Policy' document to match the GDPR.
We also wrote up a DPIA document about our internal systems.
All of this work took time - perhaps about the equivalent of 2-3 weeks to plan, collate and draw the diagrams and workflows for things like our security incident response plan and how we would sub-process subject rights requests; like when a client receives a 'Right to erasure' request and asks for assistance.
Overall that work was not difficult and did not cause any headaches. What has been a pain has been responding to all the clients who send us various compliance 'questionnaires' (spreadsheets) expecting tailored responses - fortunately, in the main I was able to answer "see document ref xxxxxx, section nnn".
What I am seeing now is the late-arrivals throwing in (demanding) 'for compliance' every conceivable infosec feature they have read up about - one today insisted we must now implement in-memory encryption! Many of these recent demands are not mandated by the GDPR and so are being handled as contractual changes and new feature requests so the sales team are having discussions to explain our stance and see if the customer wants a quote to amend their service and contract!