Data Protection Policy
1. Purpose and Scope
Define the purpose: Ensure compliance with applicable data
protection laws (e.g., GDPR, CCPA).
Scope: Describe which data and stakeholders (employees,
customers, vendors) are covered.
2. Roles and Responsibilities
Assign responsibilities for data governance, including:
o Data Protection Officer (DPO) – Ensures compliance with
regulations.
o Information Security Team – Oversees the protection of
personal data.
o All Employees – Follow policies and report incidents.
(Refer to ISO 27002: A.5.2 for information security roles and
responsibilities.)
3. Definitions
Personal Data: Any information that can identify an individual (e.g.,
name, email, IP address).
Data Subject: The individual to whom the personal data pertains.
Processing: Any operation on personal data, such as collection,
storage, or sharing.
4. Data Classification and Handling
Classify data based on confidentiality, integrity, and availability
(aligned with ISO 27002: A.5.12 on data classification).
Label and restrict access according to data sensitivity levels.
5. Legal and Regulatory Compliance
Identify relevant regulations (e.g., GDPR, CCPA) and embed
compliance into operations (ISO 27001: A.5.31).
Maintain a privacy notice to inform stakeholders of their rights and
data usage (ISO 27002: A.5.34).
6. Data Collection and Use
Describe lawful and transparent methods for data collection.
Ensure data minimization by collecting only what is necessary.
7. Data Storage and Retention
Specify where data will be stored and retention periods.
Define secure disposal methods for outdated or unnecessary data.
8. Access Control and Security Measures
Limit data access to authorized personnel only (ISO 27002: A.5.15
on access control).
Use encryption, multi-factor authentication, and other technical
controls.
9. Third-Party Data Sharing
Establish data-sharing agreements with third parties.
Conduct due diligence on vendors to manage risks (ISO 27002:
A.5.19).
10. Data Subject Rights
Outline procedures to handle:
o Access requests.
o Rectification or deletion of personal data.
o Objections to data processing.
11. Incident Management and Breach Notification
Establish procedures for managing data breaches, including
timelines for notifying regulatory bodies (ISO 27002: A.5.24).
12. Monitoring and Auditing
Conduct regular audits to ensure compliance with the policy and
relevant laws (ISO 27001: A.5.35).
13. Training and Awareness
Provide regular training to employees on data protection practices
and updates (ISO 27002: A.6.3 on awareness training).
14. Policy Review and Updates
Review and update the policy periodically or when significant
changes occur (ISO 27002: A.5.1 on policy management).
Data Protection Policy
Effective Date: [Insert Date]
Reviewed Date: [Insert Date]
Policy Owner: [Department/Person responsible]
Version: 1.0
1. Purpose
This policy sets out how [Organization Name] collects, stores, processes,
and protects personal data to comply with relevant data protection
regulations, such as the General Data Protection Regulation (GDPR)
or California Consumer Privacy Act (CCPA), and ensure alignment
with ISO 27001/27002 requirements.
2. Scope
This policy applies to:
All personal data collected and processed by the organization,
including employee, customer, vendor, and third-party data.
All staff, contractors, and third parties who access personal data
within [Organization Name].
Data processing in both digital and physical forms.
3. Definitions
Personal Data: Any information relating to an identifiable person
(e.g., name, address, email, IP address).
Data Subject: The individual whose personal data is being
processed.
Processing: Any operation performed on personal data (e.g.,
collection, storage, sharing, deletion).
Data Controller: The entity that determines the purposes and
means of data processing.
Data Processor: The entity that processes data on behalf of the
Data Controller.
4. Roles and Responsibilities
Data Protection Officer (DPO): Ensures compliance with data
protection laws and oversees policy implementation.
All Employees: Follow this policy and report any data breaches.
Information Security Team: Maintain technical controls to protect
personal data.
(Aligned with ISO 27002: A.5.2 on roles and responsibilities.)
5. Data Collection and Use
Collect only the personal data necessary for specific, lawful
purposes.
Inform data subjects about the purpose and legal basis of data
collection via privacy notices.
Obtain explicit consent where required (e.g., for marketing
communications).
Ensure data is not processed beyond its intended purpose.
6. Data Classification and Protection
Classify data based on sensitivity (e.g., public, internal,
confidential).
Encrypt personal data in storage and during transmission.
Apply access control principles to restrict data access to authorized
personnel only (ISO 27002: A.5.15 on access control).
7. Data Retention and Deletion
Store personal data only for the period necessary to fulfill its
purpose.
Dispose of data securely when no longer required (e.g., data
shredding or permanent deletion).
8. Data Subject Rights
[Organization Name] respects the following data subject rights:
Access: Provide copies of their personal data upon request.
Rectification: Correct inaccurate or incomplete data.
Erasure: Delete data upon request when legally permissible.
Objection: Allow individuals to object to certain processing
activities (e.g., marketing).
Data Portability: Enable data transfer to another service provider
upon request.
9. Data Sharing with Third Parties
Data shared with external vendors must be governed by data
processing agreements.
Conduct regular audits to verify third-party compliance with data
protection requirements (ISO 27002: A.5.19 on supplier relationships
).
10. Data Breach Management
Report any data breach immediately to the DPO.
Notify regulatory authorities and affected data subjects within
[insert number] hours if required by law.
Maintain an incident management plan (ISO 27002: A.5.24 on
incident management).
11. Training and Awareness
All employees must receive regular training on data protection and
their responsibilities.
New hires must complete data protection training as part of
onboarding (ISO 27002: A.6.3 on awareness training).
12. Monitoring and Compliance
Conduct internal audits to monitor compliance with this policy and
relevant data protection laws.
Report non-compliance to management, with corrective actions
implemented promptly (ISO 27001: A.5.36 on compliance
monitoring).
13. Policy Review and Updates
This policy will be reviewed annually or when significant changes
occur, such as new regulations or business processes.
Any changes to the policy must be approved by [Insert
Name/Department].
14. Contact Information
For questions regarding this policy, please contact:
Data Protection Officer: [Insert Name and Contact Details]
Approval:
Authorized by: [Insert Approver’s Name and Title]
This example ensures that the organization meets legal obligations, aligns
with ISO 27001/27002 standards, and follows best practices for protecting
personal data. Implementing such a policy contributes to compliance,
reduces risks, and enhances stakeholder trust.
