Posted in Indemnification and Advancement Most senior corporate executive have a general understanding of the importance to them of their corporate indemnification rights. As I have noted in prior posts refer for example herean issue that frequently recurs is question of when the company may withhold advancement.
In this case the intent is to curb some of the worst excesses in terms of privacy violation by corporate entities and to put control over their data back in the hands of the owners of that data: Regular readers of my blog know that privacy is a subject that is dear to me and as such I welcome the GDPR and hope that the law will have its intended effect.
Ironically, these companies are breaking the law by sending these messages… Privacy is an important thing, it is so important that the framers of the Universal Declaration of Human Rights saw fit to include it in their short list of things that everybody should have.
Kinds of data Data comes in many different kinds, there is data associated with a person an individual and there is data that is not associated with a particular individual. This means that to all intents and purposes you should focus on data associated with a particular individual.
Examples of such profile data are your social media postings, your medical history including your x-rays, the data an advertising agency keeps on you and so on. What the GDPR clarifies and which was already the law anyway, but which companies routinely ignored is that you are not the owner of that data.
You are merely the steward of the data, and that holding the data is a liability to your business. And being a proper steward of that data requires all kinds of processes to be in place which you should have had anyway!
If that sounds like a burden to you then yes, you are right, it is a burden. But then again, data life-cycle management makes good sense, after all if you are hanging on to data that you have no business having or if you refuse to correct wrong data or if you refuse to tell people what you have on them then your company is not acting in the interest of the people whose data it holds.
And that is a key item: Their interests are legitimate, but secondary. The kinds of data that companies hold will have a significant impact on the burden of the GDPR, as a rule, the more critical the data to the individual, the higher the burden.
So the burden for data that is already public is relatively small or non-existent. The burden for data that is highly confidential, such as your medical records or your financial dealings is much higher. Of course not all banks were equally concerned with this and some banks will see a larger amount of work under the GDPR than before.
And one hospital may have done a better job in the past than another.
This goes for businesses just the same, those businesses that already had their house in order and that have automated procedures in place and that in general have put themselves in the position of being stewards rather than owners of the data they hold are likely in a good position when it comes to dealing with the GDPR.
Then there is the kind of data that has special consideration: It is everything that allows you to find out who the data is about. Examples of obvious PII are full names and social security numbers. And many more examples like that. The simplest solution is to deal with all data that you hold on an individual as though it is PII.
Better safe than sorry. But if you feel you must treat some of your users data in a different way then you need to carefully weigh what data you treat as PII and what data you are more cavalier with. Quantity of data Companies that have thousands of records of data for instance: For that reason such companies which are most likely larger anyway will have to expend more effort and will have face a larger burden to become compliant than the smaller ones.
Yes, the aforementioned life-cycle management is going to be the same amount of work for a small company as it is for a large one, but if you could do the work to collect the data there is no excuse for not properly managing it.
But that is your bookkeeping, which probably has little to no direct connection to your live web services, and is only concerned with actual sales and refunds. Size of the organization The burden of compliance on a small organization will be lower because having a dedicated DPO data protection officer or CCO chief compliance officer is not going to be required for SMEs unless they deal with very large volumes of data or deal with very sensitive data.
But very small companies say a 1 person company dealing with extremely high risk data would do well to consider at least hiring an outsider for a bit to ensure that they are not exposed to extreme risks.
In some cases, for very small entities processing very small amounts of non-critical data a DPO may not be required at all.Provide the nuts and bolts of government organization, outlines government powers and any limitations on those powers. is the law of the land.
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What does a comprehensive and enforceable lease look like? This panel will discuss how to get the most out of your lease, without drafting a page contract. The Nuts and Bolts of Contract Management.
Nov 30, PM - PM Charles Hayes Family Investment Center (FIC), Cisco Lab - S Wabash, Chicago. Publications Branding: The Nuts and Bolts of Creating and Protecting a Company Logo. Aug 17, First published in the Hawai‘i Bar Journal (the official publication of the Hawai‘i State Bar Association), August Edition.
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