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The Manager's Data protection Duties (Paperback)
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The Manager's Data protection Duties (Paperback)
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Each manager of a department, or a specific responsibility, must
assess the data issues and risks as are relevant to their
individual department. The manager must assess what data exists;
whether it is permitted for use; filter out (including deletion of)
data that is over-broad or otherwise not permitted; and ensuring
procedures to identify and eliminate processes that open up the
risk of future unjustified data collections. While other agents of
the company or organisation will have responsibilities in relation
to data protection compliance, the manager of a department must
also engage in best practices that focus on the data protection
obligations of the department. Data protection compliance requires
not just adherence to specific data protection legal provisions,
but a full understanding of what data exists in the department,
company or organisation, where it is located and for what purpose.
The personnel manager needs to be satisfied that all of the
internal personnel records are fully data protection complaint.
Just one of the dangers is that these issues are not addressed in
appropriate reviews, contracts and policies. Another risk gap is
that there may be policies, etc., but the manager omitted to
appropriately include other non full time employees, such as those
whom may be contractors, temporary staff, interns, or family
members. The marketing manager needs to be satisfied that all of
the current and proposed marketing activities, customer lists, and
user lists are all compliant with the new data protection rules.
Organisations should have undergone an A - Z review of data
protection compliance in the lead up to the new EU General Data
Protection Regulation (GDPR) go-live date. In many organisations
there will be many activities and actions which carried over from
the GDPR review. These need to continue to be actioned. In
addition, there is also a new Data Protection Act 2018 to consider.
Organisations should also have appointed a new Data Protection
Officer (DPO) to assist in these efforts and to be the official
point of contact internally and externally (for data protection
supervisory authorities and for customers and users). Critically,
all Managers need to be aware of data protection compliance and
related issues within their own Department. The Manager has duties
and responsibilities. The Manager cannot simply assume that someone
else will do it, or that all data protection issues for their
Department are already being dealt with by the DPO or some other
Department.
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