Data Protection Lifecycle Management // IT Management Solutions

Data Protection Lifecycle Management

lifecycleIn January this year, the European Commission presented its proposal for a new data protection regulation in Europe. The new regulation has the potential to bring the existing framework up to date with technological and societal developments and may even outlive the life expectancy of the 17 year-old existing data protection framework.

However, in my opinion, the proposal as it stands at the moment is still only a patchwork of good ideas. It is lacking an overall comprehensive approach making sure that we achieve actually enforceable standards, which guarantee that the fundamental rights of our citizens remain respected on one hand, and on the other allows for innovative business models to be developed.

In order to achieve this synergy, we need a more congruent concept that lays down a strong, logical, effective and enforceable set of rules. At the same time, this concept has to incentivize businesses to invest in the protection of personal data throughout the entire data lifecycle from collection to processing to destruction.
In consequence, I have developed the concept of “Lifecycle Data Protection Management (Lifecycle DPM)”, based on a simple stick and carrot principle: Invest from the outset in a sustainable data management framework, follow it up with a comprehensive compliance mechanism and you will be rewarded with an effective implementation and enforcement architecture.

1. Sustainable data management framework
1.1. Systematic data protection by design practices
Prerequisite for a sustainable data protection framework are systematic data protection by design practices. As the proposed regulation correctly points out, businesses shall implement appropriate technical and organizational measures that ensure the protection of personal data, both at the time when the means for processing are determined and at the time of the processing itself. In addition, I believe that in order to foster its widespread implementation in different economic sectors, data protection by design needs to be a prerequisite for public procurement tenders.

Furthermore, data protection by design shall not only have regard to the state of the art and the cost of implementation, but also to the potential risks posed by data processing. Also, data protection by design shall have particular regard to the entire lifecycle management of personal data, systematically focusing on comprehensive procedural safeguards regarding the accuracy, confidentiality, integrity, physical security and destruction of personal data.

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Prentice Hall Data Protection and Information Lifecycle Management
Book (Prentice Hall)
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