It's easy for your customers to correct or update inaccurate or incomplete information. If you've dutifully worked to the bottom of the GDPR checklist then you've significantly limited your exposure to regulatory penalties. Your business has conducted an information audit to map data flows. Your data subjects can request to restrict or stop processing of their data if certain grounds apply, mainly if there's some dispute about the lawfulness of the processing or the accuracy of the data. If you think that applies to you, you'll need to set up a procedure to ensure you are protecting their rights, freedoms, and legitimate interests. UK GDPR), has identified audit as having a key role to play in educating and assisting organisations to meet their obligations. You should be able to comply with requests under Article 16 within a month. 0000025743 00000 n 0000003914 00000 n The europa.eu webpage concerning GDPR can be found here. Controllers checklist. Er stellt keine Rechtsberatung dar und kann auch keine Rechtsberatung ersetzen. It's easy for your customers to request to have their personal data deleted. ����k*,w��ѣ0�z�8�JL2��!�i�K荌�5�^HUX�����eX�JT���d���-b�|�O|�"�� Share (Opens Share panel) Step 1 of 4: Lawfulness, fairness and transparency. H�|Wˮe9 ����c$v�a;���0@��U-~���d'�\D��׍?���~�������n�W������}�w��2�w��_�z��+�~��׿����������n���!ޤ޵�C�/�ߚl~?��+���[��vX�vk�W)�~^��?\NwJ0�v���2��z��?�{���*�έA��ɭ_?D� The ICO's data protection self assessment toolkit helps you assess your organisation's compliance with data protection law and helps you find out what you need to do to make sure you are keeping people’s personal data secure. We provide a checklist of key questions data controllers and data processors need to ask themselves at the start of a data audit process to prepare for GDPR compliance May 2017 The first steps towards GDPR compliance are understanding your obligations, what your current processes are and identifying any gaps. You can manage the items in this checklist with Compliance Manager by referencing the Control ID and Control Title under Customer Managed Controls in the GDPR tile. The best way to demonstrate GDPR compliance is using a data protection impact assessment Organizations with fewer than 250 employees should also conduct an assessment because it will make complying with the GDPR's other requirements easier. 0000046961 00000 n 0000024828 00000 n The GDPR requires organizations to carry out this kind of analysis whenever they plan to use people's data in such a way that it's "likely to result in a high risk to [their] rights and freedoms." �z�2��U�b0���x�P]�"P��]/������@�4��w��e�p�f�8UH� �HJqF�}�Snbh1C�C.�* ��!g%�F���rↅ�P�}E��:����)�aQ��$ GąuЫG��ľ�7�6Y=b������A/�@���s���8%.,T���p���r�j��Q��ڝ@Y@2.no/AR��б�^�&4F�8J�Jb p� ���:X鲣��)���*Ǧ/p����xfp'�Pz`����,����k��^� The GDPR requires organizations to carry out this kind of analysis whenever they plan to use people's data in such a way that it's "likely to result in a high risk to [their] rights and freedoms." GDPR Checklist Check out our GDPR checklist! %PDF-1.4 %���� Finally, we want to remind you once more that this checklist is not in any way legal advice. Create a security policy that ensures your team members are knowledgeable about data security. This may seem unfair from a business standpoint in that you may have to turn over your customers' data to a competitor. 0000024453 00000 n The Guide to the GDPR, published by the U.K. Information Commissioner's Office, explains the provisions of the GDPR to help organizations comply with its requirements, along with a 12-step checklist that can be used to prepare for the GDPR. Bought in lists. This checklist is based on a released Data Protection Authority (DPA) GDPR Audit checklist. Cookie-Richtlinie Datenschutzerklärung (3 The DPO should be an expert on data protection whose job is to monitor GDPR compliance, assess data protection risks, advise on data protection impact assessments, and cooperate with regulators. It must be presented "in a concise, transparent, intelligible and easily accessible form, using clear and plain language, in particular for any information addressed specifically to a child.". ?��!�QPa���`��F(���Ch��š��ס.J��c~�����h���t/ߕDC$�ٿQL/��Lu�=P�2���Ě �� �����ꩈ-f��6D��&I��-�z� The UK Information Commissioner's Office (ICO) has a data protection impact assessment checklist on its website. For those in English-speaking non-EU countries, you may find it easiest to notify the Office of the Data Protection Commissioner in Ireland. Congratulations! endstream endobj 18 0 obj <> endobj 19 0 obj <>/MediaBox[0 0 595.276 841.89001]/Parent 14 0 R/Resources<>/Font<>/ProcSet[/PDF/Text]>>/Rotate 0/TrimBox[0 0 595.27557 841.88977]/Type/Page/u2pMat[1 0 0 -1 0 841.88977]/xb1 0/xb2 595.27557/xt1 0/xt2 595.27557/yb1 0/yb2 841.88977/yt1 0/yt2 841.88977>> endobj 20 0 obj <>/Border[0 0 0]/H/N/Rect[21.77698 530.95477 41.508 521.95477]/Subtype/Link/Type/Annot/URI(https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/)>> endobj 21 0 obj <>/Border[0 0 0]/H/N/Rect[152.33099 515.95477 172.06097 506.95477]/Subtype/Link/Type/Annot/URI(http://www.slcc.co.uk/course/data-protection/36/)>> endobj 22 0 obj <>/Border[0 0 0]/H/N/Rect[72.76599 465.95477 93.02502 456.95477]/Subtype/Link/Type/Annot/URI(http://www.slcc.co.uk/content/gdpr-presentation/696/)>> endobj 23 0 obj <>/Border[0 0 0]/H/N/Rect[60.01202 385.95477 80.64801 376.95477]/Subtype/Link/Type/Annot/URI(http://www.slcc.co.uk/content/came-and-company-gdpr-documents/699/)>> endobj 24 0 obj <>/Border[0 0 0]/H/N/Rect[161.12402 315.95477 181.76001 306.95477]/Subtype/Link/Type/Annot/URI(http://www.slcc.co.uk/content/gdpr-advice-notes/698/)>> endobj 25 0 obj <>/Border[0 0 0]/H/N/Rect[21.77698 145.95477 112.32397 136.95477]/Subtype/Link/Type/Annot/URI(http://www.slcc.co.uk/content/gdpr-advice-notes/698/)>> endobj 26 0 obj <>/Border[0 0 0]/H/N/Rect[110.52399 145.95477 130.784 136.95477]/Subtype/Link/Type/Annot/URI(http://www.slcc.co.uk/content/gdpr-model-schedules/697/)>> endobj 27 0 obj <>/Border[0 0 0]/H/N/Rect[21.77698 30.95477 119.95801 21.95477]/Subtype/Link/Type/Annot/URI(mailto:consultancy@slcc.co.uk)>> endobj 28 0 obj <>/Border[0 0 0]/H/N/Rect[346.32202 545.95477 366.95801 536.95477]/Subtype/Link/Type/Annot/URI(http://www.slcc.co.uk/content/gdpr-individual-rights/701/)>> endobj 29 0 obj <>/Border[0 0 0]/H/N/Rect[448.56299 414.95477 468.82202 405.95477]/Subtype/Link/Type/Annot/URI(http://www.slcc.co.uk/content/gdpr-privacy-notices/702/)>> endobj 30 0 obj <>/Border[0 0 0]/H/N/Rect[517.64099 298.95477 537.90002 289.95477]/Subtype/Link/Type/Annot/URI(http://www.slcc.co.uk/content/gdpr-model-schedules/697/)>> endobj 31 0 obj <>/Border[0 0 0]/H/N/Rect[432.55505 188.95477 452.81396 179.95477]/Subtype/Link/Type/Annot/URI(http://www.slcc.co.uk/content/gdpr-subject-access-procedures/703/)>> endobj 32 0 obj <>/Border[0 0 0]/H/N/Rect[480.729 78.95477 500.98901 69.95477]/Subtype/Link/Type/Annot/URI(http://www.slcc.co.uk/content/gdpr-individual-rights/701/)>> endobj 33 0 obj <> endobj 34 0 obj <>stream You need to make it easy for people to request human intervention, to weigh in on decisions, and to challenge decisions you've already made. 0000055743 00000 n � �L B�0[h4�p>�d�`�l;����E������ '�Y�U���Y{�9>�{�/�g� �� �+xA�bbU���;�� "? 0000053567 00000 n In other words, data protection is something you now have to consider whenever you do anything with other people's personal data. 0000012045 00000 n The Guide to the GDPR, published by the U.K. Information Commissioner's Office, explains the provisions of the GDPR to help organizations comply with its requirements, along with a 12-step checklist that can be used to prepare for the GDPR. This accountability readiness checklist provides a convenient way to access information you may need to support the GDPR when using Microsoft Office 365. Some types of organizations use automated processes to help them make decisions about people that have legal or "similarly significant" effects. It's easy for your customers to receive a copy of their personal data in a format that can be easily transferred to another company. You should only use third parties that are reliable and can make sufficient data protection guarantees. Create an internal security policy for your team members, and build awareness about data protection. A list of many of the EU member states supervisory authorities can be found here. If you continue to use this site we will assume that you are happy with it. �S*��̈�י�f$,6Ti#(��h�r�� 0I$bYܮ�M�JJA2%�xDGE#���H����"-�� 0000003437 00000 n What is compliance? communicate data breaches to your data subjects. 0000002164 00000 n There is more detail behind each issue noted below. There are big changes on the way. Employees who have access to personal data and non-technical employees should receive extra training in the requirements of the GDPR. If you're processing their data for the purposes of direct marketing, you have to stop processing it immediately for that purpose. xref You can find this information on our What is GDPR? encryption), and when you plan to erase it (if possible). Organizations that have at least 250 employees or conduct higher-risk data processing are required to keep an up-to-date and detailed list of their processing activities and be prepared to show that list to regulators upon request. 0000018319 00000 n People generally have the right to ask you to delete all the personal data you have about them, and you have to honor their request within about a month. It should include guidance about email security, passwords, two-factor authentication, device encryption, and VPNs. Until this requirement is interpreted, it may be prudent to designate a representative in a member state that uses your language. Our GDPR checklist can help you secure your organization, protect your customers’ data, and avoid costly fines for non-compliance. Are you ready for the GDPR? The checklist can be cross referenced to the infographic chart produced by the FSB (Federation of Small Businesses) and available on the Rotary GDPR webpages as a resource guide. Since every business is different and the GDPR takes a risk-based approach to data protection, companies should work to assess their own data collection and storage practices (including the ways they use HubSpot’s marketing and sales tools), seek their own legal advice to ensure that their business practices comply with the GDPR. In your list, you should include: the purposes of the processing, what kind of data you process, who has access to it in your organization, any third parties (and where they are located) that have access, what you're doing to protect the data (e.g. � ���$e���2��/��R52�$�!P0�>�P��,`��������&�d�����Sl�>��\�`��F9#Q=K! The ICO recommends just doing it anytime you're about to process personal data. There are three circumstances in which organizations are required to have a Data Protection Officer (DPO), but it's not a bad idea to have one even if the rule doesn't apply to you. Compliance is relatively straight-forward, and only requires taking a few pragmatic steps to align with GDPR’s policies. The GDPR requires organizations to use encryption or pseudeonymization whenever feasible. To help you prepare we have developed this GDPR checklist based on the latest information available. Even if your technical security is strong, operational security can still be a weak link. 0000001504 00000 n You should make sure you have the right procedures in place to detect, report and investigate a personal data breach. L���� z6U���{Z)��k)��J:n�[�L�a��X�r�(�Ɲ4�W�b����M�Ο�+�^�È�ac��E��siXqXw�@-+V(���Ë����w���q����Y��wI���o�G� T/;!���o�Q�;A@Z*�Ϲ����H�� |���I�q Bs(���u��cD���~�~��5�8�;v��+��H��B�H�Ѵ3A@D1��J����Z ��6�i�Ï��ځ��κ��cÌ�c�=6/�i��Nt�o|elށ֘�Fȇ��� �ptkX��'TÊ�a�~��R�In����ՙ3~�uW�Ws����z8� �G�$�u��@� ���Q�B}���C�O�[w� ?Fȇ��� �pti؁��i;TÊ�ae��㤹5������ճ��h?^j�[�l��ƚ��V�=����7j/s��{��9U��r6�:��m�����TY"�u�K��='����:&l��u*���f\B`Co�dӆ`{ v7n]�2: �&B��� If you make decisions about people based on automated processes, you have a procedure to protect their rights. If there's a data breach and personal data is exposed, you are required to notify the supervisory authority in your jurisdiction within 72 hours. 0000002702 00000 n All Rights Reserved. GDPR compliance is easier with encrypted email. <]/Prev 74123>> There are other provisions related to children and special categories of personal data in Articles 7-11. Review these provisions, choose a lawful basis for processing, and document your rationale. 0000001156 00000 n • a Getting ready for the GDPR toolkit. GDPR.EU is a website operated by Proton Technologies AG, which is co-funded by Project REP-791727-1 of the Horizon 2020 Framework Programme of the European Union. Your business will need to manage, administer and protect personal data whether you work in B2B or B2C marketing. Obtaining consent for marketing We use opt-in boxes We specify methods of communication (eg by email, text, phone, recorded call, post) We ask for consent to pass details to third parties for marketing and name those third parties We record when and how we got consent, and exactly what it covers . 0000025465 00000 n trailer Have you taken the necessary measures to comply with the GDPR (General Data Protection Regulation)?If you're not prepared, you're certainly not alone. You should be able to comply with such requests within a month. 0000038500 00000 n The checklist is not an explanation of the law or the extent of obligations on either controllers or processors under GDPR. A GDPR DPIA Assessment. Nothing found in this portal constitutes legal advice. It summarises the key points you need to know, answers frequently asked questions, and contains practical checklists to … The EU GDPR will apply to an organisation established outside of the EU, so long as the organisation offers goods or services to individuals in the EU, or monitors their behaviour within the EU. However, it is not a substitute for specific professional advice. 0000026519 00000 n Have a legal justification for your data processing activities. But from privacy standpoint, the idea is that people own their data, not you. Download Ico Gdpr And Consent doc. You should check with a lawyer to make sure your organization fully complies with the GDPR. People have the right to see what personal data you have about them and how you're using it. Given the sweeping nature of the changes coming under GDPR, it’s no surprise that there is a feeling of mild panic in some circles about the ability to be compliant by May. Processing of data is illegal under the GDPR unless you can justify it according to one of six conditions listed in Article 6. In fact, following through with plans for sustainable GDPR compliance can have many long-term benefits for your organization. Der GDPR (DSGVO) Übersicht des ICO; Die Checkliste des ICO; Die (aktuell) 8-teilige Reihe zum Thema DSGVO von Medienrechtsanwältin Nina Diercks; Dieser Artikel dient der Information zum Thema DSGVO. 0000005426 00000 n 0000003673 00000 n You should explain how the data is processed, who has access to it, and how you're keeping it safe. The GDPR Audit Checklist provides a general framework for large and medium-sized organizations to assess their implementation of the GDPR requirements. Check out the ICO’s checklist for an idea of what a plan might entail. The ICO, which is the Brit government agency responsible for enforcing Britain's rather weak data laws, has issued guidance for companies to seek redemption ahead of the EU GDPR rules coming into force in the UK this May. No matter how broad or deep you want to go or take your team, ISACA has the structured, proven and flexible training options to take you from any level to new heights and destinations in IT audit, risk management, control, information security, cybersecurity, IT governance and beyond. J�4��BC7)��b��[����ެde��C�ֲ�&��)70��{�S&ўAb�V�S �I} !�S���}��H�8���y��eT��1 �hk��2�t{������\�(�2�m>g)�d�Z�X0^�S-�&6�� �\��:��+@��� g":���J ����;x���v� ~#9�Z=���C���`�M`�^Ǥ�Ě�q��7�iK�ǡ��m=�. Step 2 – information you hold You will need to plan a Data Audit* which will document the information you hold about children, families and staff. Have a process in place to notify the authorities and your data subjects in the event of a data breach. Conduct an information audit to determine what information you process and who has access to it. No Issue Tasks 1 Corporate Governance a . Download Ico Gdpr And Consent pdf. You need to tell people that you're collecting their data and why (Article 12). COMPLIANCE TOOLKIT . Compliance Toolkit . 0000004102 00000 n 0000001423 00000 n To accelerate your existing efforts, we’ve distilled everything you need to do to achieve and maintain GDPR compliance into this simple nine-step checklist. 0000004592 00000 n Papers published by the ico and consent as consent Articles in place but this consent should take extra care over is the copyright law. Note that if you choose "consent" as your lawful basis, there are extra obligations, including giving data subjects the ongoing opportunity to revoke consent. The European Union General Data Protection Regulation (EU GDPR)1 replaces the EU Directive2 and will enter into force from 25 May 2018. Viele Unternehmen sind sich angesichts der neuen Regulierungen nicht … GDPR.eu is co-funded by the Horizon 2020 Framework Programme of the European Union and operated by Proton Technologies AG. It explains each of the data protection principles, rights and obligations. There are dozens of provisions in the GDPR that apply only in rare instances, which would be counterproductive to cover here. You must notify the data subject before you begin processing their data again. For BCRs already approved under the GDPR, the new BCR Lead SA in the EEA, as the new competent Supervisory Authority (“SA”) in accordance with Article 47.1 GDPR, will have to issue a new approval decision following an opinion from the EDPB before the end of the transition period. Mayer Brown offers this list of some issues to consider when reviewing your third-party vendor agreements for compliance with the GDPR. The point is that it needs to be something you and your employees are always aware of. Fax +356 25 707 099. 0000026221 00000 n We use cookies to ensure that we give you the best experience on our website. Provide clear information about your data processing and legal justification in your privacy policy. Tipico Group Ltd. Tipico Tower Vjal Portomaso St. Julian’s STJ 4011 Malta. The ICO checklist indicates that organisations should document what personal data is held, where it comes from and who the organisation shares it with. 59 0 obj <>stream h�b``�f``�����`�� �� @16�s�20�8 �1X�NO�2+�\6���fc��H1v4���� �Ě`�P^�� 0000003200 00000 n Make sure you can verify the identity of the person requesting the data. The following checklist helps to ensure that the M&A process complies with data protection rules. checklist. This is a great starter checklist. GDPR compliance in a data-driven world Insights from a 2018 survey Compliance doesn’t have to be a scary word, even when facing the multifaceted challenges of the European Union’s General Data Protection Regulation. 0000002937 00000 n z�ɨ! Technical measures include encryption, and organizational measures are things like limiting the amount of personal data you collect or deleting data you no longer need. There are a five grounds on which you can deny the request, such as the exercise of freedom of speech or compliance with a legal obligation. (GDPR). A Data Protection Impact Assessment (DPIA) is a process whereby potential privacy issues and risks … Rotary - GDPR Preparation Checklist This 12-point checklist is designed to assist Rotary clubs and districts in preparing themselves for GDPR. 0 Introduction: The new General Data Protection Regulation (GDPR) determines how your business does business from May 2018. It is important that a professional evaluation and weighting of the requisite individual measures is undertaken and documented. right to see what personal data you have about them. This person should be empowered to evaluate data protection policies and the implementation of those policies. GDPR Checklist for … %%EOF It's easy for your customers to ask you to stop processing their data. 0000031703 00000 n A GDPR Audit checklist. 0000004349 00000 n 0000027048 00000 n Please keep in mind that nothing on this page constitutes legal advice. You must also try to verify the identity of the person making the request. The full obligations contained in the GDPR should be consulted to check compliance against each issue. You also need to make sure any processing of personal data adheres to the data protection principles outlined in Article 5. If you process data relating to people in one particular member state, you need to appoint a representative in that country who can communicate on your behalf with data protection authorities. 0000025550 00000 n This GDPR checklist for businesses is built on the basis of official ICO guidelines and recommendations.. Right to Erasure Request Form GDPR Checklist. H6���� An information audit will be an important step to form the basis of the ‘records of processing’ required under Article 30 of the GDPR. The vast majority of services have a standard data processing agreement available on their websites for you to review. This includes any third-party services that handle the personal data of your data subjects, including analytics software, email services, cloud servers, etc. The GDPR and its official supporting documents do not give guidance for situations where processing affects EU individuals across multiple member states. They spell out the rights and obligations of each party for GDPR compliance. We recommend you speak with an attorney specialized in GDPR compliance who can apply the law to your specific circumstances. It covers the UK General Data Protection Regulation (UK GDPR), tailored by the Data Protection Act 2018. 0000026726 00000 n 0000004835 00000 n GDPR CHECKLIST FOR CEOS CEO ORGANISATION I take a front seat and ensure that my board fully supports and understands GDPR We have a Data Protection Officer or a dedicated go-to resource to manage our obligations under the GDPR We know which and how departments will be impacted across the business We have assessed and updated Make sure you keep up with payments to ICO – they are still the regulator of GDPR in the same way Ofsted regulates the EYFS. To understand the GDPR checklist, it is also useful to know some of the terminology and the basic structure of the law. Make sure you can verify the identity of the person requesting the data. Appoint a Data Protection Officer (if necessary). Some organizations, like public bodies, are not required to appoint a representative in the EU. REGULATION (GDPR) THE ICO CHECKLIST OF STEPS TO TAKE NOW SLCC’S ADVICE AS HOW TO PROCEED 2 INFORMATION YOU HOLD . If your organization is outside the EU, appoint a representative within one of the EU member states. 17 43 0000025253 00000 n 17 0 obj <> endobj You are required to honor their request within about a month. ISACA ® is fully tooled and ready to raise your personal or enterprise knowledge and skills base. 0000025649 00000 n Encrypt, pseudonymize, or anonymize personal data wherever possible. GDPR For App Developers: The Checklist GDPR is about holding companies accountable for their data handling and privacy practices. Do your best to keep data up to date by putting a data quality process in place, and make it easy for your customers to view (Article 15) and update their personal information for accuracy and completeness. A model procedure is available here You should start thinking now about whether you need to put systems in place to verify individuals’ ages … Designate someone responsible for ensuring GDPR compliance across your organization. Otherwise, you may be able to challenge their objection if you can demonstrate "compelling legitimate grounds.". "�E�\��HD��j'����( Our quick start guide will help you to understand the process and controls your organisation needs to implement to ensure GDPR compliance. 0000033858 00000 n 0000042539 00000 n a spreadsheet) either to them or to a third party they designate. Privacy Policy. Another part of "data protection by design and by default" is making sure someone in your organization is accountable for GDPR compliance. Additional information on Rotary and GDPR, including some of the … 1.1 Information you hold . Sign a data processing agreement between your organization and any third parties that process personal data on your behalf. The UK Information Commissioner's Office (ICO) has a data protection impact assessment checklist on its website. It's easy for your customers to request and receive all the information you have about them. It's easy for your customers to object to you processing their data. Take data protection into account at all times, from the moment you begin developing a product to each time you process data. 0000005098 00000 n The checklist contains a list of items that your organization should consider including in your privacy statement to ensure compliance with Articles 13 and 14 of the GDPR. Using this checklist will help you structure your business to adhere to the GDPR. This information should be included in your privacy policy and provided to data subjects at the time you collect their data. The ICO recommends just doing it anytime you're about to process personal data. 0000026842 00000 n A data protection impact assessment (aka privacy impact assessment) is a way to help you understand how your product or service could jeopardize your customers' data, as well as how to minimize those risks. While processing is restricted, you're still allowed to keep storing their data. This means that you should be able to send their personal data in a commonly readable format (e.g. © 2021 Proton Technologies AG. Always be an unambiguous action should in certain cases consent framework is important to require the online. If "legitimate interests" is your lawful basis, you must be able to demonstrate you have conducted a privacy impact assessment. Data Processing Agreement You must follow the principles of "data protection by design and by default," including implementing "appropriate technical and organizational measures" to protect data. You have to send them the first copy of this information for free but can charge a reasonable fee for subsequent copies. GDPR: Article 28 Checklist Pursuant to Article 28, contracts between controllers and processors (and processors and subprocessors) must do the steps included in this downloadable checkist. 0000005341 00000 n 0000002473 00000 n Most of the productivity tools used by businesses are now available with end-to-end encryption built in, including email, messaging, notes, and cloud storage. restrict or stop processing of their data. 0000026019 00000 n Know when to conduct a data protection impact assessment, and have a process in place to carry it out. This is not an official EU Commission or Government resource. 0000055649 00000 n The GDPR does not specify whom you should notify if you are not an EU-based organization. You are also required to quickly communicate data breaches to your data subjects unless the breach is unlikely to put them at risk (for instance, if the stolen data is encrypted). They also have a right to know how long you plan to store their information and the reason for keeping it that length of time. startxref Sind Sie bereit für die DSGVO? 0000000016 00000 n 0000036051 00000 n page. To stop processing it immediately for that purpose the person requesting the data Technologies! Lawful basis, you have to consider when reviewing your third-party vendor for! In B2B or B2C ico gdpr checklist pdf not give guidance for situations where processing affects EU individuals across multiple member supervisory... For subsequent copies the time you process and controls your organisation needs to something. Have their personal data an official EU Commission or Government resource that a professional evaluation and weighting of the protection. 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