Wednesday, July 11, 2012

Mr. Director, there is an inspector Data Protection In The Door ... what do we do?


At any time, virtually without warning (as the element of surprise is a trick to playing in the AEPD), an inspector may come in the door of your company willing to dig through your documents, access databases, make copies as it deems appropriate, review the places you will find the files, request written models and ask plenty of proofs that it considers appropriate. And all this without telling you exactly what you are looking for or why you are inspecting. Would you know how to act?

DATA PROTECTION In PractiLetter have prepared a guide only to face an inspection of data protection. Concise, clear and full of advice, which will move a couple of them:

DO NOT miss a minute. Since his company receives notice of the AEPD indicating that your company will be visiting until inspectors have very little time available, only a few hours. You must make the most of the inspection to meet in the best conditions. They have not said who is the complainant or the reason for the visit (ie, what possible violation has been committed by your company) but perhaps I can guess. Have you had any previous complaint of a client or an employee? Try to identify the possible violation to prepare your "defense". Check all procedures related to data protection it has in your company, make sure they have the security document and that it is updated (probably asked it), enable a space and the technical means to allow the inspector access to the database without disrupting the normal activity of your company. If they have registered all the files that should have, do so urgently. Use electronic means to be recorded before the appearance of the inspector.



PRESENCE OF TECHNICAL REPORT? TICO. The inspectors do not require a computer technician is present during the inspection, but only the controller. But since that will access your computer system and its data files, perhaps you will agree that the technician will guide and facilitate their work rather than the inspector has to investigate on their own, enter files that not intend to access, and so on.



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