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Cyberday content library
Data transfer and disclosure

Requirement description

How to fill the requirement

Cyberday content library

Data transfer and disclosure

Task name
Priority
Status
Theme
Policy
Other requirements
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Tasks included in the policy

Task name
Priority
Status
Theme
Policy
Other requirements
Readiness to provide a list of data transfers to the data subject
Critical
High
Normal
Low
Fully done
Mostly done
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Not done
Privacy
Data transfer and disclosure
1
requirements

Examples of other requirements this task affects

P6.7: Providing an accounting of personal information upon data subjects' request
SOC 2
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Readiness to provide a list of data transfers to the data subject
1. Task description

Upon request, the organization offers the registered person a clear list of the transfers of his personal data to third parties.

The list shows in particular which personal data has been transferred, to which organization, on what basis and when.

Rejecting any non-legally binding requests for personal data disclosure
Critical
High
Normal
Low
Fully done
Mostly done
Partly done
Not done
Privacy
Data transfer and disclosure
1
requirements

Examples of other requirements this task affects

A.8.5.5: Legally binding PII disclosures
ISO 27701
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Rejecting any non-legally binding requests for personal data disclosure
1. Task description

The organization should reject all non-legally binding personal data disclosure requests, but accept all contractually defined personal data disclosures that the customer has accepted. The relevant customer must be asked before handing over personal data.

Records of personal data disclosures to third parties
Critical
High
Normal
Low
Fully done
Mostly done
Partly done
Not done
Privacy
Data transfer and disclosure
4
requirements

Examples of other requirements this task affects

A.7.5.4: Records of PII disclosure to third parties
ISO 27701
HAL-07.1: Seuranta ja valvonta - tietojen käyttö ja luovutukset
Julkri
TEK-12.1: Turvallisuuteen liittyvien tapahtumien jäljitettävyys - tietojen luovutukset
Julkri
P6.2: Record of authorized disclosures of personal information
SOC 2
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Records of personal data disclosures to third parties
1. Task description

The organization should save information concerning personal data disclosures to third parties. The information should include what personal data has been disclosed, to whom and when.

Records of personal data transfers to third parties
Critical
High
Normal
Low
Fully done
Mostly done
Partly done
Not done
Privacy
Data transfer and disclosure
3
requirements

Examples of other requirements this task affects

A.7.5.3: Records of transfer of PII
ISO 27701
A.8.5.3: Records of PII disclosure to third parties
ISO 27701
9.5.3: Management of data transfers to third countries
TISAX
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Records of personal data transfers to third parties
1. Task description

The organization should record transfers of personal data to and from third parties. The organization should also ensure the cooperation of the relevant parties in order to enable the implementation of requests regarding obligations related to data subjects in the future as well.

The principle of data minimization must be taken into account in recordings concerning transfers and only the information that is actually needed must be kept.

Documenting states and international organizations receiving personal data
Critical
High
Normal
Low
Fully done
Mostly done
Partly done
Not done
Privacy
Data transfer and disclosure
2
requirements

Examples of other requirements this task affects

A.7.5.2: Countries and international organizations to which PII can be transferred
ISO 27701
A.8.5.2: Countries and international organizations to which PII can be transferred
ISO 27701
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Documenting states and international organizations receiving personal data
1. Task description

The organization should determine and document the countries and international organizations to which personal data may be transferred.

States and international organizations to which personal data can be transferred under normal circumstances must be communicated to the data subjects.

Legal bases for personal data transfers between different legal zones
Critical
High
Normal
Low
Fully done
Mostly done
Partly done
Not done
Privacy
Data transfer and disclosure
2
requirements

Examples of other requirements this task affects

A.7.5.1: Identity basis for PII transfer between jursdictions
ISO 27701
9.5.3: Management of data transfers to third countries
TISAX
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Legal bases for personal data transfers between different legal zones
1. Task description

The organization has identified possible transfers of personal data between jurisdictions.

There are identified and documented legal bases for transfers of personal data between jurisdictions.

Documentation of data disclosures for data stores
Critical
High
Normal
Low
Fully done
Mostly done
Partly done
Not done
Privacy
Data transfer and disclosure
10
requirements

Examples of other requirements this task affects

12. Transparent information, communication and modalities for the exercise of the rights of the data subject
GDPR
28. Data processor
GDPR
30. Records of processing activities
GDPR
A.6.2: Recording of PII disclosures
ISO 27018
A.7.3.7: PII controllers' obligations to inform third parties
ISO 27701
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Documentation of data disclosures for data stores
1. Task description

The data in a data store are, in principle, only available to that controller and under the same responsibility. If you pass data on to another organization for other use, you must clearly inform about it and state e.g. the recipient of the transfer and the legal basis.

Documentation of bases for personal data transfer for relevant partners
Critical
High
Normal
Low
Fully done
Mostly done
Partly done
Not done
Privacy
Data transfer and disclosure
16
requirements

Examples of other requirements this task affects

44. General principle for transfers
GDPR
45. Transfers on the basis of an adequacy decision
GDPR
46. Transfers subject to appropriate safeguards
GDPR
47. Binding corporate rules
GDPR
48. Transfers or disclosures not authorised by Union law
GDPR
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Documentation of bases for personal data transfer for relevant partners
1. Task description

GDPR defines the conditions for the lawful transfer of personal data outside the EU or the EEA.

The organization shall document all data transfers and the applicable transfer criteria. Data transfers can occur, for example, based on the location of the data system, the data processing partner or the recipient of the data disclosure.

Inventory and documentation of data processing agreements
Critical
High
Normal
Low
Fully done
Mostly done
Partly done
Not done
Privacy
Data transfer and disclosure
16
requirements

Examples of other requirements this task affects

28. Data processor
GDPR
13.2.2: Agreements on information transfer
ISO27 Full
15.1.2: Addressing security within supplier agreements
ISO27 Full
A.8.2.4: Infringing instruction
ISO 27701
5.14: Information transfer
ISO27k1 Full
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Inventory and documentation of data processing agreements
1. Task description

The processors of personal data (e.g. providers of data systems, other partners using our employee or customer data) and the agreements related to the processing of personal data have been documented. The documentation includes e.g.:

  • Processor name and location
  • Purpose of processing data
  • Status of agreement

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1.1 (MIL2): Manage IT and OT Asset Inventory
C2M2: MIL1
1.1 (MIL3): Manage IT and OT Asset Inventory
C2M2: MIL1
1.1.1: Availability of information security policies
TISAX
1.1.1: Identify the organisation’s strategy and priorities
NSM ICT-SP
1.1.2: Identify the organisation’s structures and processes for security management
NSM ICT-SP
1.1.3: Identify the organisation’s processes for ICT risk management
NSM ICT-SP
1.1.4: Identify the organisation’s tolerances for ICT risk
NSM ICT-SP
1.1.5: Identify the organisation’s deliverables, information systems and supporting ICT functions
NSM ICT-SP
1.1.6: Identify information processing and data flow
NSM ICT-SP
1.2 (MIL2): Manage Information Asset Inventory
C2M2: MIL1
1.2 (MIL3): Manage Information Asset Inventory
C2M2: MIL1
1.2.1: Establish a process to identify devices and software in use at the organisation
NSM ICT-SP
1.2.1: Scope of Information Security management
TISAX
1.2.2: Establish organisational guidelines for approved devices and software
NSM ICT-SP
1.2.2: Information Security Responsibilities
TISAX
1.2.3: Identify devices in use at the organisation
NSM ICT-SP
1.2.3: Information Security requirements in projects
TISAX
1.2.4: Definition of responsibilities with service providers
TISAX
1.2.4: Identify the software in use at the organisation
NSM ICT-SP
1.2: Manage Information Asset Inventory
C2M2: MIL1
1.3 (MIL2): Manage IT and OT Asset Configuration
C2M2: MIL1
1.3 (MIL3): Manage IT and OT Asset Configuration
C2M2: MIL1
1.3.1: Identification of information assets
TISAX
1.3.1: Identify the users of the information systems
NSM ICT-SP
1.3.2: Classification of information assets
TISAX
1.3.2: Identify and define the different user categories
NSM ICT-SP
1.3.3: Identify roles and responsibilities linked especially to ICT security
NSM ICT-SP
1.3.3: Use of approved external IT services
TISAX
1.3.4: Use of approved software
TISAX
1.3: Manage IT and OT Asset Configuration
C2M2: MIL1
1.4 (MIL2): Manage Changes to IT and OT Assets
C2M2: MIL1
1.4 (MIL3): Manage Changes to IT and OT Assets
C2M2: MIL1
1.4.1: Management of Information Security Risks
TISAX
1.4: Manage Changes to IT and OT Assets
C2M2: MIL1
1.5 (MIL1): Management Activities for the ASSET domain
C2M2: MIL1
1.5 (MIL2): Management Activities for the ASSET domain
C2M2: MIL1
1.5 (MIL3): Management Activities for the ASSET domain
C2M2: MIL1
1.5.1: Assessment of policies and requirements
TISAX
1.5.2: External review of ISMS
TISAX
1.5: Management Activities for the ASSET domain
C2M2: MIL1
1.6.1: Reporting of security events
TISAX
1.6.2: Management of reported events
TISAX
1.6.3: Crisis preparedness
TISAX
10 §: Johdon vastuu
KyberTL
10. Processing of personal data relating to criminal convictions and offences
GDPR
10.1 (MIL2): Establish Cybersecurity Program Strategy
C2M2: MIL1
10.1 (MIL3): Establish Cybersecurity Program Strategy
C2M2: MIL1
10.1.1: Policy on the use of cryptographic controls
ISO27 Full
10.1.2: Key management
ISO27 Full
10.1.2: Key management
ISO 27017
10.1: Continuous improvement
ISO27k1 Full
10.1: Cryptographic controls
ISO27 Full
10.1: Cryptographic controls
ISO 27017
10.1: Establish Cybersecurity Program Strategy
C2M2: MIL1
10.2 (MIL2): Establish and Maintain Cybersecurity Program
C2M2: MIL1
10.2 (MIL3): Establish and Maintain Cybersecurity Program
C2M2: MIL1
10.2: Establish and Maintain Cybersecurity Program
C2M2: MIL1
10.2: Non-conformity and corrective action
ISO27k1 Full
10.3 (MIL1): Management Activities for the PROGRAM domain
C2M2: MIL1
10.3 (MIL2): Management Activities for the PROGRAM domain
C2M2: MIL1
10.3 (MIL3): Management Activities for the PROGRAM domain
C2M2: MIL1
10.3: Management Activities for the PROGRAM domain
C2M2: MIL1
10: Cryptography
ISO27 Full
10: Cryptography
ISO 27017
10: Cybersecurity Program Management (PROGRAM)
C2M2: MIL1
10: Prosessi väärinkäytöksiin reagoimiseksi
Sec overview
11 §: Poikkeamailmoitukset viranomaiselle
KyberTL
11. Processing which does not require identification
GDPR
11.1.1: Physical security perimeter
ISO27 Full
11.1.2: Physical entry controls
ISO27 Full
11.1.3: Securing offices, rooms and facilities
ISO27 Full
11.1.4: Protecting against external and environmental threats
ISO27 Full
11.1.5: Working in secure areas
ISO27 Full
11.1.6: Delivery and loading areas
ISO27 Full
11.1: Secure areas
ISO27 Full
11.2.1: Equipment siting and protection
ISO27 Full
11.2.2: Supporting utilities
ISO27 Full
11.2.3: Cabling security
ISO27 Full
11.2.4: Equipment maintenance
ISO27 Full
11.2.5: Removal of assets
ISO27 Full
11.2.6: Security of equipment and assets off-premises
ISO27 Full
11.2.7: Secure disposal or re-use of equipment
ISO27 Full
11.2.7: Secure disposal or re-use of equipment
ISO 27017
11.2.8: Unattended user equipment
ISO27 Full
11.2.9: Clear desk and clear screen policy
ISO27 Full
11.2: Equipment
ISO27 Full
11.2: Equipment
ISO 27017
11: Digiturvan mittarien määrittäminen
Sec overview
11: Physical and environmental security
ISO27 Full
11: Physical and environmental security
ISO 27017
12 §: Luotettavuutta edellyttävien tehtävien tunnistaminen ja luotettavuudesta varmistuminen
TiHL
12 §: Poikkeamaa koskeva väliraportti
KyberTL
12. Transparent information, communication and modalities for the exercise of the rights of the data subject
GDPR
12.1.1: Documented operating procedures
ISO27 Full
12.1.2: Change management
ISO27 Full
12.1.3: Capacity management
ISO27 Full
12.1.4: Separation of development, testing and operational environments
ISO27 Full
12.1: Operational procedures and responsibilities
ISO27 Full
12.2.1: Controls against malware
ISO27 Full
12.2: Protection from malware
ISO27 Full