Privacy Ref Blog
Breach Notification and Follow Up
Unfortunately, it is a given that as an organization you will receive a notice from a third party that they had an incident or breach that may have compromised personal or sensitive employee or customer information. A majority of the breach laws require immediate notification or notification within a 24hr to 48hr timeframe, not including notification times from a contractual perspective. The question then becomes what does the third party need to provide, the level of assurance in order for an organization to re-establish connectivity and/or to use third-party moving forward.
From an organization’s perspective, there is no easy answer. Contractually there will requirements for the notification and remediation but not specifics on what the third party needs to provide, documentation or otherwise than the notice. I would recommend the following approach:
- Obtain a copy of the incident report. Notices, in general, do not provide a detailed explanation or will be provided well after an incident has occurred. Transparency is key to reestablish trust with the third party.
- Obtain any internal or external audit documentation. This will allow you to see how the incident report aligns with the controls or lack thereof previously identified by the internal or external audit.
- Obtain any security assessment /security audit documentation. This will include any vulnerability testing and penetration testing. Generally speaking, you will receive pushback from this, but a signed NDA will curtail potential confidentiality and disclosure concerns.
- Require an audit, at a minimum, 6 months after remediation to ensure that the new or remediated environment matches the remediation. This will need to be performed by an independent third party.
- Ensure that the third party completes a SOC 2 Type 1 or 2 report for full testing of the Trusted Service Principles. Granted this will be dependent on the type of services that the third party is providing as well as taking into consideration that this type of report will take at least 6 to 9 months to complete.
Privacy Ref provides consulting and assessment services to build and improve organizational privacy programs. For more information call Privacy Ref at (888) 470-1528 or email us at firstname.lastname@example.org Posted on April 30, 2018 by Jen Spencer
Want to find out more?
Simply go to the contact page, fill out the form, and someone from Privacy Ref will be in touch with you. You can also send an email to email@example.com or call (888) 470-1528.
April 16, 2018
IAPP Training Classes
Privacy Ref is proud to announce that we are an official training partner of the IAPP. You now have the opportunity to learn from one of our knowledgeable privacy professionals using the most respected training content in the industry. The robust interactive training offered, aids in the understanding of critical privacy concepts. The contents of the courses are integral to obtaining your privacy certifications and to educate your new team. Learn more here
Latest Blog Posts
September 19, 2018
My wife and I went to a favorite pizza place the other day. It is a small chain that has a loyalty program. The server, having seen us on a few other occasions, asked us if we wanted to sign up. All we needed to do was provide an email address, phone number, and name then we would be good to go.
Continue reading this post...
August 27, 2018
With many of us so busily focused on compliance with the European Union’s General Data Protection Regulation (“GDPR”) - and probably soon to be focused on the new California Consumer Privacy Act - it is easy to neglect (albeit inadvertently) other areas of the world. If you are a company with international operations or are collecting the personal information of non-EU foreign residents, this could be a costly mistake.
Continue reading this post...
Other Recent Posts