March 11, 2019

The Global Privacy Enforcement Network’s (GPEN) annual intelligence gathering operation looked at how well organisations have implemented the core concepts of accountability into their own internal privacy policies and programmes.

The joint study, known as the “GPEN sweep”, is carried out by data protection regulators across the globe and this year looked at how they have taken responsibility for complying with data protection laws.

The Information Commissioner’s Office said that whilst there were examples of good practice, the “sweep” found that a number of organisations had no processes in place to deal with the complaints and queries raised by data subjects and were not equipped to handle data security incidents appropriately.

ICO Head of Intelligence, Adam Stevens, said:

“The findings suggest that whilst organisations contacted by the ICO and our international partners have a good understanding of the basic concept of accountability, in practice there is significant room for improvement.

“It is important that organisations have appropriate technical and organisational measures in place. This includes having clear data protection policies, taking a ‘data protection by design and default’ approach and continuing to review and monitor performance and adherence to data protection rules and regulations.”

Participating GPEN members made contact with 356 organisations in 18 countries during the “sweep” and came to the following conclusions:

• when it comes to monitoring internal performance in relation to data protection standards, many organisations fell short, and around a quarter who responded had no programmes in place to conduct self-assessments and/or internal audits;
• organisations were generally found to be quite good at giving data protection training to staff, but often failed to provide refresher training to existing staff;
• organisations that indicated that they have monitoring programmes in place generally gave examples of good practice, noting that they conduct annual audits or reviews and/or regular self-assessments;
• nearly three quarters of organisations across all sectors and jurisdictions had appointed an individual or team who would assume responsibility for ensuring that their organisation complies with relevant data protection rules and regulations; and
• over half of the organisations surveyed indicated that they have documented incident response procedures, and that they maintain up to date records of all data security incidents and breaches. However, a number of organisations indicated that they have no processes in place to respond appropriately in the event of a data security incident.

In terms of national findings, the ICO made contact with 28 organisations across various sectors in the UK, and came to the following conclusions:

• only 67% of organisations who provided a response said that they conduct regular self-assessments or audits of internal data protection standards and practices, and only 67% indicated that they maintain inventories of personal data held;
• 83% of UK organisations who responded to the ICO’s queries indicated that they have implemented an internal data privacy policy and ensure that staff receive data protection training; and
• 100% of organisations in the UK who provided a response indicated that they felt they had someone within the organisation at a sufficiently senior level responsible for privacy governance and management.

As a result of the investigation, individual GPEN members may contact organisations in their own countries to assess what remedial action they need to take to improve user controls over their personal information. To read the ICO’s press release in full and to access the GPEN’s report, click here.