This policy establishes the formal framework for protecting personal data and enforcing privacy-by-design. It ensures that all data processing activities are lawful, secure, and transparent, aligning with the stringent requirements of GDPR, ISO 27001, and other key regulations.
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Achieve GDPR Compliance: Implement the core principles of the GDPR, including lawful processing, data minimization, and data subject rights management.
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Embed Privacy-by-Design: Integrate data protection into your systems and processes from the outset, reducing risks and ensuring compliance by default.
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Manage Data Subject Rights: Establish clear, auditable procedures for handling Data Subject Requests (DSRs), such as access, rectification, and erasure.
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Strengthen Data Governance: Appoint a Data Protection Officer (DPO) and assign clear roles and responsibilities for data protection across the organization.
Read Full Overview
The Data Protection and Privacy Policy is a pivotal document designed to ensure the secure and lawful handling of personal data across all organizational functions. Aligning with international standards like ISO/IEC 27001 and regulatory frameworks such as GDPR and NIS2, this policy establishes a robust governance structure for data protection. It mandates privacy-by-design and privacy-by-default principles, embedding these into all information systems and business processes. This policy provides clarity and confidence by safeguarding the organization's data assets, ensuring they are handled in a manner that meets both operational and audit needs.
What's Inside
- Purpose and Scope
- Roles and Responsibilities (DPO, CISO)
- Privacy Governance Framework
- Lawful Processing & Data Minimization
- Data Subject Rights Handling
- Breach Management & Notification
- Risk Treatment and Exceptions
Built for Leaders, By Leaders
This policy was authored by a security leader with 25+ years of experience deploying and auditing ISMS frameworks for global enterprises. It's designed not just to be a document, but a defensible framework that stands up to auditor scrutiny.
Authored by an expert holding:
Framework Compliance
🛡️ Supported Standards & Frameworks
This product is aligned with the following compliance frameworks, with detailed clause and control mappings.
| Framework | Covered Clauses / Controls |
|---|---|
| ISO/IEC 27001:2022 | Clauses 5.1, 6.1.3, 8.1, 10.1 |
| ISO/IEC 27002:2022 | Controls 5.34, 8.10, 8.11, 8.12 |
| NIST SP 800-53 Rev.5 | AR-1, AR-2, AR-4, AR-5; PL-2, PL-8; AC-2, AC-6; AU-2, AU-6, AU-9; IR-4, IR-5, IR-6; PM-1, PM-21, PM-23 |
| EU GDPR | Articles 5, 6, 12–23, 25, 28, 30, 32–34; Recital 78 |
| EU NIS2 | Article 21(2)(e), (f) |
| EU DORA | Articles 6(2)(d), 11(1)(c), 15(1), 17 |
| COBIT 2019 | APO12, DSS01, DSS05, MEA03 |
Part of a Complete ISMS Toolkit
This policy is one of 37 documents in our complete toolkit. When implemented as a set, our framework helps you achieve comprehensive compliance across major standards.
100%
ISO 27001
95%
NIST
88%
NIS2
75%
DORA
70%
GDPR
Related Policies
This policy should be interpreted in conjunction with the following documents to ensure a holistic approach to data protection.
Information Security Policy (P1)
Establishes the overarching security governance principles.
Risk Management Policy (P6)
Defines the methodology for assessing privacy risks and conducting DPIAs.
Data Classification & Labeling Policy (P13)
Guides the categorization of personal data to apply appropriate controls.
Data Retention and Disposal Policy (P14)
Supports data minimization and erasure requirements under GDPR.
Incident Response Policy (P30)
Outlines breach response and notification timelines required by GDPR.
About This Policy
The Clarysec Data Protection and Privacy Policy is an essential governance document for any organization handling personal data. It provides a comprehensive framework to ensure your data processing activities are lawful, transparent, and secure, directly addressing the core requirements of the EU General Data Protection Regulation (GDPR). This policy establishes accountability through defined roles, including a Data Protection Officer (DPO), and mandates the maintenance of a Record of Processing Activities (ROPA).
By embedding privacy-by-design and privacy-by-default principles into your operations, this policy helps you build systems and processes that are inherently compliant. It provides structured procedures for managing data subject rights, conducting Data Protection Impact Assessments (DPIAs), and handling personal data breaches. Implementing this policy demonstrates a clear commitment to privacy, building trust with customers and satisfying the stringent requirements of auditors and regulators.
