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General Data Protection Regulation
24. Responsibility of the controller

Requirement description

How to fill the requirement

General Data Protection Regulation

24. Responsibility of the controller

Task name
Priority
Status
Theme
Policy
Other requirements
Data system listing and owner assignment
Critical
High
Normal
Low
Fully done
Mostly done
Partly done
Not done
System management
Data system management
49
requirements

Examples of other requirements this task affects

5. Principles relating to processing of personal data
GDPR
24. Responsibility of the controller
GDPR
28. Data processor
GDPR
32. Security of processing
GDPR
44. General principle for transfers
GDPR
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Data system listing and owner assignment
1. Task description

Organisation must maintain a listing of used data systems and their owners. Owner is responsible for completing the related documentation and possible other security actions directly related to the data system.

Data system documentation must include at least:

  • System purpose and linked responsibilities
  • System's data location (covered in a separate task)
  • System's maintenance and development responsibilities and linked partners (covered in a separate task)
  • When necessary system's access roles and authentication methods (covered in a separate task)
  • When necessary systems interfaces to other systems (covered in a separate task)
Personnel guidelines for reporting security incidents
Critical
High
Normal
Low
Fully done
Mostly done
Partly done
Not done
Incident management
Incident management and response
38
requirements

Examples of other requirements this task affects

24. Responsibility of the controller
GDPR
16.1.2: Reporting information security events
ISO27 Full
16.1.3: Reporting information security weaknesses
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T06: Turvallisuuspoikkeamien hallinta
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6.4: Menettelytavat virhe- ja ongelmatilanteissa
Self-monitoring
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Personnel guidelines for reporting security incidents
1. Task description

A process for reporting incidents is maintained to help staff report incidents efficiently and consistently.

Things to report as an incident include e.g.:

  • unauthorized access to data / premises
  • action against security guidelines
  • suspected security issue (e.g. phishing, malware infection)
  • data system outage
  • accidental or intentional destruction / alteration of data
  • lost or stolen device
  • compromised password
  • lost physical identifier (e.g. keychain, smart card, smart sticker)
  • suspected security weakness (e.g. on utilized data system or other procedures)

The personnel guidelines emphasize the obligation to report security incidents as soon as possible in accordance with the agreed process. The instructions also describe other operations in the event of an incident (e.g. recording seen error messages and other details).

Identification and documentation of cyber security risks
Critical
High
Normal
Low
Fully done
Mostly done
Partly done
Not done
Risk management and leadership
Risk management
39
requirements

Examples of other requirements this task affects

5. Principles relating to processing of personal data
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24. Responsibility of the controller
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13 §: Tietoaineistojen ja tietojärjestelmien tietoturvallisuus
TiHL
T04: Turvallisuusriskien hallinta
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ID.GV-4: Processes
NIST
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Identification and documentation of cyber security risks
1. Task description

The organization proactively seeks to list and assess the likelihood and severity of various cyber security risks. The documentation shall include the following:

  • Description of the risk
  • Evaluated impact and likelihood of the risk
  • Tasks for managing the risk or other treatment options
  • Acceptability of the risk
Regular reviewing of data system access rights
Critical
High
Normal
Low
Fully done
Mostly done
Partly done
Not done
System management
Access control and authentication
30
requirements

Examples of other requirements this task affects

5. Principles relating to processing of personal data
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24. Responsibility of the controller
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32. Security of processing
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9.2.5: Review of user access rights
ISO27 Full
16 §: Tietojärjestelmien käyttöoikeuksien hallinta
TiHL
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Regular reviewing of data system access rights
1. Task description

Data system owner determines the access roles to the system in relation to the tasks of users. The compliance of the actual access rights with the planned ones must be monitored and the rights reassessed at regular intervals.

When reviewing access rights, care must also be taken to minimize admin rights and eliminate unnecessary accounts.

Incident management resourcing and monitoring
Critical
High
Normal
Low
Fully done
Mostly done
Partly done
Not done
Risk management and leadership
Cyber security management
12
requirements

Examples of other requirements this task affects

24. Responsibility of the controller
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7.2.1: Management responsibilities
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16.1.1: Responsibilities and procedures
ISO27 Full
5.24: Information security incident management planning and preparation
ISO27k1 Full
Article 17: ICT-related incident management process
DORA
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Incident management resourcing and monitoring
1. Task description

Management shall define responsibilities and establish procedures to ensure an effective and consistent response to security incidents.

Management must ensure e.g.:

  • interference management has clear responsibilities
  • there is a documented process for responding, handling and reporting incidents

The process must ensure e.g.:

  • staff have a clear contact point / tool and instructions for reporting incidents
  • the reported security breaches will be addressed by qualified personnel in a sufficiently comprehensive manner
Management commitment to cyber security management and management system
Critical
High
Normal
Low
Fully done
Mostly done
Partly done
Not done
Risk management and leadership
Cyber security management
26
requirements

Examples of other requirements this task affects

24. Responsibility of the controller
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5.1.1: Policies for information security
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7.2.1: Management responsibilities
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7.2.2: Information security awareness, education and training
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ID.GV-1: Cybersecurity policy
NIST
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Management commitment to cyber security management and management system
1. Task description

The organization's top management must demonstrate a commitment to cyber security work and the management system. Management commits to:

  • defining the frameworks or other requirements that form the basis for work (e.g. customer promises, regulations or certificates)
  • determining the resources needed to manage security
  • communicating the importance of cyber security
  • ensuring that the work achieves the desired results
  • promoting the continuous improvement of cyber security

Top management also decides the scope of the information security management system and records the decision in the description of the system. This means, for example, whether some parts of the organisation's activities or information are excluded from the scope of the management system, or whether it applies to all information / activities of the organization.

Documentation of linked risks for identified security incidents
Critical
High
Normal
Low
Fully done
Mostly done
Partly done
Not done
Risk management and leadership
Risk management
12
requirements

Examples of other requirements this task affects

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21.2.a: Risk management and information system security
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8.3: Information security risk treatment
ISO27k1 Full
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Documentation of linked risks for identified security incidents
1. Task description

Organization assesses cyber security risks by responding to situations where security has been mildly or severely compromised. The documentation shall include at least the following:

  • Description of the incident
  • Risks associated with the incident
  • New tasks introduced as a result of the incident
  • Other measures taken due to the incident
Process for initiating data breach treatment
Critical
High
Normal
Low
Fully done
Mostly done
Partly done
Not done
Incident management
Data breach management
9
requirements

Examples of other requirements this task affects

24. Responsibility of the controller
GDPR
32. Security of processing
GDPR
16.1.5: Response to information security incidents
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16.1.7: Collection of evidence
ISO27 Full
5.26: Response to information security incidents
ISO27k1 Full
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Process for initiating data breach treatment
1. Task description

Our organization has pre-defined procedures through which the detected security breach will be addressed. The process may include e.g. the following things:

  • who are part of a team that is ready to respond to breaches
  • how and along what channel the entire team is immediately notified of the breach
  • the team determines the severity (low, medium, high) of the breach based on predefined criteria
  • the breach management is continued with a larger group according to the severity level
Defining security roles and responsibilities
Critical
High
Normal
Low
Fully done
Mostly done
Partly done
Not done
Risk management and leadership
Cyber security management
33
requirements

Examples of other requirements this task affects

24. Responsibility of the controller
GDPR
6.1.1: Information security roles and responsibilities
ISO27 Full
T02: Turvallisuustyön tehtävien ja vastuiden määrittäminen
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ID.AM-6: Cybersecurity roles and responsibilities
NIST
ID.GV-2: Cybersecurity role coordination
NIST
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Defining security roles and responsibilities
1. Task description

Top management must ensure clear responsibilities / authority on at least the following themes:

  • who is primarily responsible for ensuring that the information security management system complies with the information security requirements
  • who act as ISMS theme owners responsible for the main themes of the information security management system
  • who has the responsibility and authority to report to top management on the performance of the information security management system
  • who is authorized to carry out internal audits

The ISMS theme owners are presented on the desktop of the management system and in the Information security policy report.

In addition, top management shall ensure that all roles relevant to information security, as well as related responsibilities and authorities, are defined and communicated. It is also important to recognize the roles and responsibilities of external partners and providers.

Tasks included in the policy

Task name
Priority
Status
Theme
Policy
Other requirements
No items found.

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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
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1.3.3: Use of approved external IT services
TISAX
1.3.4: Use of approved software
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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
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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