Customer statement and notification feed

Process personal data lawfully, fairly and in a transparent manner; collect it for specified, explicit and legitimate purposes and do not process it further in a way incompatible with those purposes; keep it adequate, relevant and limited to what the purpose needs; keep it accurate and up to date, erasing or rectifying inaccurate data without delay; keep it in a form permitting identification no longer than the purpose requires; and secure it against unauthorised or unlawful processing and against accidental loss, destruction or damage using appropriate technical or organisational measures. The controller is responsible for all six principles and must be able to demonstrate compliance with them.

What an assessor asks to see: The purpose recorded for each processing activity, stated specifically enough that a later use can be tested against it; Retention schedule per data category with the criteria that set each period, and deletion evidence showing the schedule actually runs; Minimisation analysis per collection point showing why each field is necessary for the stated purpose; Accuracy controls: how inaccurate data is detected, and records of rectification or erasure carried out without delay. Where it usually falls short: Purposes written so broadly, for example business purposes or service improvement, that no later use could ever be incompatible with them

Financial entities shall put in place an ICT business continuity policy and ICT response and recovery plans (including measures, procedures and arrangements) to ensure continuity of critical or important functions, quickly contain damage, resume activities and recover, subject to regular testing.

What an assessor asks to see: ICT business continuity policy + response/recovery plans; Records of plan testing. Where it usually falls short: No ICT continuity/response/recovery plans

Document and maintain business continuity plans that guide teams through response and recovery, collectively containing the actions to continue or recover prioritized activities within predetermined time frames, the means of monitoring the disruption and the response, the pre defined thresholds and process for activating the response, procedures to deliver products and services at agreed capacity, and how the immediate consequences are managed with regard to individual welfare, prevention of further loss and environmental impact; each plan must state purpose, scope and objectives, the roles and responsibilities of the implementing team, the actions implementing the solutions, the supporting information needed to activate, operate, coordinate and communicate including activation criteria, internal and external interdependencies, resource requirements, reporting requirements and a stand down process, and must be usable and available at the time and place it is needed.

What an assessor asks to see: Plan set with each plan carrying every required element; Activation criteria and thresholds stated in the plan itself; Interdependency and resource sections reconciled to the BIA; Stand down process defined. Where it usually falls short: Plans that cover activation and response but have no stand down, so the organization never formally returns to normal