"There is no favorable wind for the
sailor who does not know where to go" Seneca
Through a complete and in-depth analysis of the Company's
status quo (PDCA process) we focus on the lacks of corporate policy to
identify all the actions needed to define Privacy Policy and the most
appropriate Corporate governance model according to the personal data
protection provisions - D.Lgs. 196/2003.
Our consultancy addresses the following key areas:
- Privacy Policy;
- Communications and Training;
- Privacy Management;
- Security measures;
- Privacy Compliance;
- Information and Consent;
- Cross-EU data flows;
- Response procedures for data subject requests.
Consequently, the main areas of intervention
are:
- Company information system assessment;
- Identification of modifications needed;
- Definition and classification of types of data processed;
- Definition of data processing terms and method;
- Definition of the minimum security measures to adopt and residual
risk;
- Definition of processing offices tasks and duties;
- Definition of processing organizational and technical procedures;
- Writing the Internal Code regarding employees personal data processing
in respect of Articles 4 and 8 Workers' Statute;
- Writing the letters of information and consent;
- Writing the appointment letters for internal and external data processors;
- Definition of the Company Privacy Policy;
- Drafting of the Security Policy Documents (SPD - DPS) according to
All. B - D.Lgs. 196/2003;
- Analysis of transfer of personal data to third countries: contractual
solutions and BCRs (Binding Corporate Rules);
- Training for Data Controllers, Data Processors, Managers, persons
in charge of the processing: basic course on general risks, course
on specific risks, ongoing routine and training;
- Legal advices.
Training
We are fond of emphasizing the importance
of Training time in a company as:
- An opportunity to transmit the corporate
ethical values;
- A moment to involve the staff in organizational and
management choices;
- Pillar of any Corporate Governance Model whose preventing
efficacy must be able to exclude that subjects working within the organization
could justify the committee of an offence by pleading ignorance of
the Corporate Policy.
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