Mini Bundle: Data Protection & Privacy - SME

The 'Mini Bundle: Data Protection & Privacy - SME' is a comprehensive suite of six tightly integrated policies designed for small and mid-sized enterprises to fulfill critical data protection, privacy, and compliance mandates. All policies in this bundle are explicitly tailored for SMEs (as indicated by the policy numbering with 'S' and the use of the General Manager as the principal accountability role), recognizing limited staffing resources or the absence of large, dedicated IT, security, or compliance departments. Despite these structural constraints, these policies have been meticulously crafted to meet the stringent requirements of ISO/IEC 27001:2022, ISO/IEC 27002:2022, the EU GDPR, EU NIS2 Directive, EU DORA Regulation, NIST SP 800-53 Rev.5, and COBIT 2019. This bundle ensures end-to-end coverage of the entire data lifecycle. The Data Classification & Labeling Policy (P13S) establishes an SME-appropriate, enforceable three-tier classification model, including labeling requirements and technical controls. It provides clear roles for the General Manager, Data Managers, IT support (internal/outsourced), and all employees/contractors, emphasizing practical visibility (headers, watermarks, tags) and compliance duties. Closely linked, the Data Retention & Disposal Policy (P14S) mandates legal- and business-driven retention periods with a centrally managed Retention Register, explicit secure disposal techniques (shredding, digital wipe, cryptographic erase), and rigorous documentation of exceptions and legal holds, again with policy oversight feasible even in small organizations. For data minimization and processing outside production environments, the Data Masking & Pseudonymization Policy (P16S) requires that real personal or sensitive data never be used when not strictly needed, such as in testing or analytical use, by enforcing transformation controls (masking, tokenization, pseudonymization). All transformation processes are required to be auditable, using only IT-approved tools with logs and key management, ensuring traceability down to individual datasets and events. Core to the bundle, the Data Protection & Privacy Policy (P17S) captures all legal obligations for personal data, encompassing staff, client, and third-party records. It enforces privacy by design and by default, lawful collection and minimization, secure retention, clear access review, and handling of individual data subject rights. Responsibilities are clearly apportioned among the General Manager (as DPO/Privacy accountable), Privacy Coordinator (internal/outsourced), IT provider, and all operational staff. Training, consent, escalation, and breach notification are integrated, as are alignment checks with related classification, retention, masking, and incident handling policies. Managing external risks, the Third-Party & Supplier Security Policy (P26S) sets compulsory requirements for supplier vetting, risk analysis, access restriction, contract clauses (including breach SLAs and audit rights), and ongoing oversight. It addresses all typical SME third-party scenarios (IT, SaaS, business operations, etc.), mandating supplier acceptance of contract terms, regular reviews, and secure offboarding or data destruction post-termination. Finally, the Audit & Compliance Monitoring Policy (P33S) streamlines the process of internal audits, security control checks, and regulatory review. Designed for use without specialist auditors, it empowers the General Manager and IT provider to use checklists and keep evidence logs to ensure operational readiness for ISO/IEC 27001 certification or customer/vendor due diligence. Audit trails, corrective action documentation, and compliance evidence are required to be centralized and available for at least two years, supporting defensible governance even for SMEs with minimal compliance staffing. Taken together, this mini bundle operationalizes leading standards and privacy laws into actionable, business-practical controls, providing a robust, audit-ready data protection and privacy regime that is easy for SMEs to implement and maintain.