Category: DPO Blog

Category: DPO Blog

Morrisons NOT vicariously liable for employee data protection breach says UK Supreme Court
01/04/2020 CISO Blog, DPO Blog, Security Advisory Blog EditoratLarge

Firstly – This is legal information of general interest and does not constitute legal advice of any kind. On April 1, 2020, the UK Supreme Court today handed down their judgement in the case of WM Morrisons Supermarkets plc (Appellant) v Various Claimants (Respondent), case UKSC 2018/0213. The Supreme Court unanimously ruled that Morrisons were not

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Calculating Risk – Where’s your Confidence?!
05/03/2020 CISO Blog, DPO Blog, Operational Resilience Blog, Security Advisory Blog EditoratLarge

When helping organisations navigate risk management Fox Red Risk is often faced with the task of determining methods for calculating risk. We prefer to use tried and tested methodologies but what we often find is that organisations, very rarely, are calculating risk properly. A key thing missing from the majority of implementation we see is

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Asset Discovery for Cybersecurity & Data Protection – You can’t protect it if you don’t know it exists!
03/02/2020 CISO Blog, DPO Blog, Operational Resilience Blog, Security Advisory Blog EditoratLarge

There is an old management adage that what isn’t measured isn’t managed. It’s so true. Something similar applies to cybersecurity. If you don’t know an asset exists, how on earth can you protect that asset from a cyber-attack or data breach?! Asset Discovery is the number one exercise a new CISO (or Virtual CISO) should

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Processor Contract – How Data Processors can inadvertently become Controllers…and why it matters!
27/01/2020 DPO Blog, Operational Resilience Blog, Security Advisory Blog EditoratLarge

For those of you who deal with the wonderful document that is a data processor contract. Whether you’re on the Controller side or the Processor side, you will know there are quite a few hoops to jump through. This is because GDPR strengthened the requirements of a Controller-Processor relationship, outlined in Article 28. That said,

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GDPR Subject Access – why verifying ID can be dangerous!
20/01/2020 DPO Blog, Security Advisory Blog EditoratLarge

wrote a few weeks ago discussing how DSAR volumes may have gone up in your organisation and that it’s probably not simply down to the GDPR Subject Access hurdles being lowered for Data Subjects. Since GDPR came into force in May 2018, Data Subjects now don’t have to pay a fee (in most cases). The

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Supply Chain Resilience – Who are your Backup Suppliers?
13/01/2020 CISO Blog, DPO Blog, Operational Resilience Blog, Security Advisory Blog EditoratLarge

Is your supply chain resilience programme reminiscent of the article image? Aged, poorly maintained, complex, hard-to-untangle. Do you carry out due diligence at the beginning of your engagements? More importantly, do you carry out ongoing governance and oversight? Even more importantly, does supply chain resilience form part of your wider operational resilience strategy or business

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DSAR – Help I can’t cope!!! Our Subject Access Request volumes have gone through the roof!!!!
29/11/2019 DPO Blog, Security Advisory Blog EditoratLarge

I had an online interaction with a vendor who sells Data Subject Access Request (DSAR) automation software recently. During the ‘pitch’ they highlighted that organisations across London, UK have seen a staggering increase in DSARs since GDPR went live. An article in the Yorkshire Evening Post confirms this is not just a London-centric issue. “In

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Security Audit – Are you a ‘Quiddler’?
26/11/2019 CISO Blog, DPO Blog, Security Advisory Blog EditoratLarge

Are you a Quiddler? No, this is not some fanboi reference to Harry Potter (I’ll be honest I haven’t read one of the series, I’m a proper muggle!). Quiddling, however, is a very real problem in the world of Security Audit. If you want to know more, keep on reading. You could be one of

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Data Retention – A €14.5million fine awaits for Real Estate Data Archive non-compliant with GDPR?
05/11/2019 DPO Blog, Security Advisory Blog EditoratLarge

Data retention is always a challenge for organisations. Organisation just love retaining data and well, storage is pretty cheap these days. Whilst the costs of getting retention wrong (e.g. not being able to recover from a ransomware attack) are always high; a recent GDPR fine decision in Germany highlights the data retention problem could get

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Public Information & GDPR – I can do what I like with it…wrong!
28/10/2019 DPO Blog, Security Advisory Blog EditoratLarge

There seems to be this idea floating around that if the data is collected from publicly available sites then it is fair game for marketers. If someone has created a profile on LinkedIn for example and their email address can be harvested (say by a recruiter or data miner connecting with you) then this public

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