Written by: Narendra Sahoo
Data protection and Privacy are today the top-most priority for organizations dealing with sensitive and confidential data. There are many regulatory frameworks established around it to ensure organizations adopt industry best practices to secure their environment.
GDPR Regulation is one such framework established in the EU to ensure Data Protection and Privacy. However, due to the stringent regulation and security requirements, most organizations struggle to achieve Compliance.
For those organizations looking to achieve GDPR Compliance, implementation of ISO/IEC 27001’s framework will make your compliance journey a lot easier.
In today’s article, we have discussed how implementing ISO/IEC 27001 Standard will help in achieving GDPR Compliance.
ISO 27001 Standard and GDPR Compliance
ISO/IEC 27001 Certification is a recognized international standard for information security management. Although the standard is not exclusive to Personal Data Protection, yet many requirements are in common with the GDPR Regulation.
Implementing the ISO/IEC 27001 Standard makes it a lot easier in achieving GDPR Compliance. But, ISO/IEC 27001 and GDPR can by no means be used interchangeably. ISO/IEC 27001 simply provides a framework to ensure certain measures are implemented that also facilitates the GDPR compliance regime.
Let us take a closer look at the standard and the regulatory requirement to understand what all does ISO27001 cover in the GDPR Compliance:
What is in common between ISO 27001 Standard and GDPR Compliance?
ISO/IEC 27001 Standards can be used for achieving compliance. Given below are some standard framework that overlaps with GDPR Compliance requirements.
Risk Assessment which forms an integral part of ISO/IEC 27001 Standard, is also an essential part of GDPR Compliance. Similar to the ISO/IEC 27001 standard which includes identifying risk and applying control measures to reduce the risks to an acceptable level, GDPR requires organizations to conduct a Data Protection Impact Assessment (DPIA) to implement measures to reduce the level of risk exposure.
Implementing ISO/IEC 27001 Standard as an integrated part of your Risk Management program will also help you meet the GDPR risk assessment requirement.
Articles 33–34 of the GDPR Regulation requires organizations to notify authorities within 72 hours of a breach of personal data. Similar requirements in ISO/IEC 27001, which addresses information security incident management controls require organizations to report security incidents promptly and communicate the events in a way that facilitates timely and corrective actions to be taken.
Data Protection by Design
As under Article 25 of the GDPR Regulation organizations are required to implement technical and organizational measures that ensure data protection and privacy by design. It also requires organizations to protect data privacy by default and ensure only essential information required for a specific purpose must be processed and used.
So, Privacy by Design which is a mandatory GDPR requirement can be achieved with ISO/IEC 27001 standard which also outlines requirements to ensure information security is an integral part of information systems across the entire lifecycle.
Retention of records
The GDPR Regulation Article 30 requires organizations to maintain records of processing activities, including categorizing of data, the purpose of processing, and general description of the relevant technical and organizational security measures in place. GDPR also calls for personal information to be not stored for longer than needed.
Similarly, ISO/IEC 27001 requires organizations to document their security processes, and details of their security risk assessments and risk treatment as per Clause 8. Further, it requires information assets to be classified, inventories, and have in place procedures to ensure the use of data use is defined.
The Annex A of ISO/IEC 27001 Standard which focuses on Asset Classification and Management will also include Personal Information as Information Security Assets. This will lead organizations to classify the type of Personal Data involved, where for long is it stored, its origin, and who can access it, which are all the requirements of the GDPR. This would be in the context of handling, controlling, and/or processing Personal Information.
Can ISO 27001 Certification alone be enough for achieving GDPR Compliance?
ISO/IEC 27001 Standard is an up-and-coming industry best practice for Information Security and an excellent framework for GDPR Compliance. Organizations that implemented the standard will most likely find it easy to achieve GDPR Compliance due to the many overlapping frameworks and best practices.
Implementing the standard will help ensure the protection of Personal data and help ensure the minimization of the risk.
With many standard requirements overlapping, implementing the internationally recognized ISO/IEC 27001 standard will ease the process of compliance. Although achieving compliance to GDPR Regulation will also require the implementation of other additional security and privacy measures as stated in the GDPR Regulatory framework.
Organizations that have implemented or in the process of implementing the ISO/IEC 27001 standard are definitely in a much better position to achieve compliance with the GDPR requirements.
The proper implementation of the ISO/IEC 27001 Standard will help organizations meet quite a few overlapping requirements.
If you are considering taking this step, as experts at VISTA InfoSec we recommend organizations to perform a gap analysis to assess their current position and accordingly implement relevant controls for risk containment associated with confidentiality, integrity, and availability of personal data.
Though ISO Standards may not guarantee GDPR Compliance, it comes in handy as it provides a practical framework for developing strategies, and building comprehensive policies to minimize security risks that lead to breaches.
Organizations, in general, should consider pursuing ISO/IEC 27001 certification and GDPR for building security strong and effective measures to protect sensitive data.
Narendra Sahoo (PCI QSA, PCI QPA, CISSP, CISA, and CRISC) is the Founder and Director of VISTA InfoSec, a global Information Security Consulting firm, based in the US, Singapore & India. Mr Sahoo holds more than 25 years of experience in the IT Industry, with expertise in Information Risk Consulting, Assessment, & Compliance services. VISTA InfoSec specializes in Information Security audit, consulting and certification services which include GDPR, HIPAA, CCPA, NESA, MAS-TRM, PCI DSS Compliance & Audit, PCI PIN, SOC2 Compliance & Audit, PDPA, PDPB to name a few. The company has for years (since 2004) worked with organizations across the globe to address the Regulatory and Information Security challenges in their industry. VISTA InfoSec has been instrumental in helping top multinational companies achieve compliance and secure their IT infrastructure.