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Does your organisation have robust detection, investigation and reporting procedures in place for personal data breaches, including maintaining a record of all personal data breaches?

We log every data breach or suspected data breach. We track the date, severity and resolution.

Upon becoming aware of a security incident an assessment must be made to understand if a data breach has occurred, and if so to what extent. The assessment is broken up into 2 stages: triage and investigation. The purpose of this is to ensure that appropriate mechanisms are in place to identify when a data breach has occurred with a proportional amount of resource. The objectives of this procedure are:

• To identify if a data breach has occurred

• To identify the nature of the breach (from where it originated and if malicious, erroneous, etc)

• To identify the outcome of the breach (what has happened to the data - temporary/permanent loss, erroneous transmission to a trusted supplier, theft, accidental/malicious change)

• To identify the categories of data subject affected by the breach (clients, employees, etc)

• To identify the number of data subjects likely to be affected by the breach

• To identify the categories of data affected by the breach

• To identify if the data is likely to be used in a manner that could be detrimental to data subjects (risks to rights and freedoms)

• To identify the classification of Commonplace in relation to the affected data (Controller or Processor)

• To identify if a data breach needs to be reported to the ICO, Data Controllers or Data Subjects.

We also have a guidance document as part of our Information Security Management System.

More information: https://commonplace.atlassian.net/l/cp/qQevr3Wm