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Source : European data protection, Law and Practise, second edition 2019. An IAPP Publication.
So, what can data protection professionals do to put their organisations in the best
position possible? Where should they look to understand the meaning of ‘appropriate
technical and organisational measures’? As well as consulting with their internal
security professionals about the nature of the security threats and risks and the nature
of the response strategy, they can seek to familiarise themselves with some of the key
pieces of readily available learning. Fruitful areas for review include:
• Related pieces of the legislative framework that contain security provisions,
such as the NIS Directive, the ePrivacy Directive, the Cybercrime Directive
and the Payment Services Directive No. 2.14
• The output of institutions, such as WP29, the European Data Protection
Supervisor and the European Union Agency for Network and Information
Security.
• The output of security centres of excellence, such as the National Cyber
Security Centre in the UK.
• Policy frameworks of national governments, such as national cybersecurity
plans.
• Regulatory policy statements and other guidance issued by the national data
protection regulators and by sector regulators.
• Decisions in regulatory enforcement actions brought by the national data
protection regulators and related regulators.
• Decisions of courts and tribunals in related areas.
• National and international standards for best practice, such as the ISO 27000
series, the Payment Card Industry Data Security Standard, CBEST and the
NIST framework.
• Threat assessment reports and subject ma!er white papers published by IT
security companies and security consultants.
• The output of relevant professional associations and a'nity groups. There
are many operating in the space, such as the Cloud Security Alliance and the
Information Security Forum.
This list is not exhaustive, but it should give the data protection professional a fairly
good impression of the range of available resources in determining an appropriate level
of security.
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