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General Data Protection Regulation
17. Right to erasure (‘right to be forgotten’)

Requirement description

How to fill the requirement

General Data Protection Regulation

17. Right to erasure (‘right to be forgotten’)

Task name
Priority
Status
Theme
Policy
Other requirements
Data erasure processes and the "right to be forgotten"
Critical
High
Normal
Low
Fully done
Mostly done
Partly done
Not done
Privacy
Informing and data subject requests
7
requirements

Examples of other requirements this task affects

17. Right to erasure (‘right to be forgotten’)
GDPR
A.7.3.6: Access, correction and/or erasure
ISO 27701
A.8.2.3: Marketing and advertising use
ISO 27701
TSU-19.4: Rekisteröidyn oikeudet - Tietojen oikaiseminen, poistaminen, siirtäminen, käsittelyn rajoittaminen ja vastustaminen
Julkri
P4.3: Secure disposal of personal information
SOC 2
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Data erasure processes and the "right to be forgotten"
1. Task description

In the absence of specific situations as defined in the Data Protection Regulation, but one of the following criteria is met, the data subject has the right to have his or her personal data deleted:

  • the processing is based on consent (and there is no other reason for processing) and the data subject withdraws her consent
  • the data subject objects to the processing of his or her personal data for the purposes of direct marketing or otherwise exercises his or her right of objection and there is no valid reason for such processing
  • personal data have been collected in connection with the provision of information society services

We are aware of the situations in which the "right to be forgotten" is realized in our actions. We have designed policies for these situations, which may include e.g.:

  • the ways in which the data subject may request the deletion of data
  • the means by which the identity of the sender of the request for information is verified
  • persons assisting the contact person of the databank in processing the request
  • the means by which data are securely and permanently deleted and the data subject is informed
Documentation of conditions of consent for relevant processing purposes
Critical
High
Normal
Low
Fully done
Mostly done
Partly done
Not done
Privacy
Processing principles and accountability
8
requirements

Examples of other requirements this task affects

7. Conditions for consent
GDPR
17. Right to erasure (‘right to be forgotten’)
GDPR
A.7.2.3: Determine when and how consent is to be obtained
ISO 27701
A.7.2.4: Obtain and record consent
ISO 27701
A.7.3.4: Providing mechanism to modify or withdraw consent
ISO 27701
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Documentation of conditions of consent for relevant processing purposes
1. Task description

If our organization processes personal data based on the consent of the data subject, we must ensure that the conditions for consent are met. The conditions for lawful consent are:

  • The controller must be able to demonstrate that the data subject has consented to the processing of his or her personal data
  • The request for consent must be clearly separated from other matters in an easily comprehensible form
  • The data subject may withdraw her consent at any time and has been instructed to do so before giving her consent
  • Withdrawal of consent must be as easy as giving it

The Data Protection Officer may be responsible for assessing the conditions of consent. It is also important to consider, whether consent is generally appropriate as a legal basis for the corresponding processing.

Tasks included in the policy

Task name
Priority
Status
Theme
Policy
Other requirements
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38: Kiberuzbrukumu attiecināšana
NIS2 Latvia
1.1 (MIL2): Manage IT and OT Asset Inventory
C2M2
1.1 (MIL3): Manage IT and OT Asset Inventory
C2M2
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
1.1: Establish and Maintain Detailed Enterprise Asset Inventory
CIS 18
1.2 (MIL2): Manage Information Asset Inventory
C2M2
1.2 (MIL3): Manage Information Asset Inventory
C2M2
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: Address Unauthorized Assets
CIS 18
1.2: Manage Information Asset Inventory
C2M2
1.3 (MIL2): Manage IT and OT Asset Configuration
C2M2
1.3 (MIL3): Manage IT and OT Asset Configuration
C2M2
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
1.3: Utilize an Active Discovery Tool
CIS 18
1.4 (MIL2): Manage Changes to IT and OT Assets
C2M2
1.4 (MIL3): Manage Changes to IT and OT Assets
C2M2
1.4.1: Management of Information Security Risks
TISAX
1.4: Manage Changes to IT and OT Assets
C2M2
1.4: Use Dynamic Host Configuration Protocol (DHCP) Logging to Update Enterprise Asset Inventory
CIS 18
1.5 (MIL1): Management Activities for the ASSET domain
C2M2
1.5 (MIL2): Management Activities for the ASSET domain
C2M2
1.5 (MIL3): Management Activities for the ASSET domain
C2M2
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
1.5: Use a Passive Asset Discovery Tool
CIS 18
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
Kyberturvallisuuslaki
10. Processing of personal data relating to criminal convictions and offences
GDPR
10.1 (MIL2): Establish Cybersecurity Program Strategy
C2M2
10.1 (MIL3): Establish Cybersecurity Program Strategy
C2M2
10.1.1: Policy on the use of cryptographic controls
ISO 27001
10.1.2: Key management
ISO 27001
10.1.2: Key management
ISO 27017
10.1: Cryptographic controls
ISO 27001
10.1: Cryptographic controls
ISO 27017
10.1: Deploy and Maintain Anti-Malware Software
CIS 18
10.1: Establish Cybersecurity Program Strategy
C2M2
10.1: Non-conformity and corrective action
ISO 27001
10.2 (MIL2): Establish and Maintain Cybersecurity Program
C2M2
10.2 (MIL3): Establish and Maintain Cybersecurity Program
C2M2
10.2: Establish and Maintain Cybersecurity Program
C2M2
10.2: Configure Automatic Anti-Malware Signature Updates
CIS 18
10.2: Continuous improvement
ISO 27001
10.3 (MIL1): Management Activities for the PROGRAM domain
C2M2
10.3 (MIL2): Management Activities for the PROGRAM domain
C2M2
10.3 (MIL3): Management Activities for the PROGRAM domain
C2M2
10.3: Disable Autorun and Autoplay for Removable Media
CIS 18
10.3: Management Activities for the PROGRAM domain
C2M2
10.4: Configure Automatic Anti-Malware Scanning of Removable Media
CIS 18
10.5: Enable Anti-Exploitation Features
CIS 18
10.6: Centrally Manage Anti-Malware Software
CIS 18
10.7: Use Behavior-Based Anti-Malware Software
CIS 18
10: Cryptography
ISO 27001
10: Cryptography
ISO 27017
10: Cybersecurity Program Management (PROGRAM)
C2M2
10: Prosessi väärinkäytöksiin reagoimiseksi
Digiturvan kokonaiskuvapalvelu
11 §: Poikkeamailmoitukset viranomaiselle
Kyberturvallisuuslaki
11. Processing which does not require identification
GDPR
11.1.1: Physical security perimeter
ISO 27001
11.1.2: Physical entry controls
ISO 27001
11.1.3: Securing offices, rooms and facilities
ISO 27001
11.1.4: Protecting against external and environmental threats
ISO 27001
11.1.5: Working in secure areas
ISO 27001
11.1.6: Delivery and loading areas
ISO 27001
11.1: Establish and Maintain a Data Recovery Process
CIS 18
11.1: Secure areas
ISO 27001
11.2.1: Equipment siting and protection
ISO 27001
11.2.2: Supporting utilities
ISO 27001
11.2.3: Cabling security
ISO 27001
11.2.4: Equipment maintenance
ISO 27001
11.2.5: Removal of assets
ISO 27001
11.2.6: Security of equipment and assets off-premises
ISO 27001
11.2.7: Secure disposal or re-use of equipment
ISO 27001
11.2.7: Secure disposal or re-use of equipment
ISO 27017
11.2.8: Unattended user equipment
ISO 27001
11.2.9: Clear desk and clear screen policy
ISO 27001
11.2: Equipment
ISO 27001