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Data Protection and Compliance in Context by Stewart Room

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STAGE 1 – GATHERING INFORMATION ABOUT DATA

A data controller cannot hope to be complaint with the DPA if it does not understand its own processing operations, a point that has the greatest resonance in large organizations where personal data is gathered from a variety of sources and is subjected to a variety of processing operations and for a variety of different purposes. Thus, the initial stages of a compliance strategy are always dominated by the following key questions:

  • What personal data are being processed?

  • Whose personal data are being processed?

  • Why are personal data being processed?

  • How are personal data being processed?

The first question causes the data controller to identify the categories of information being processed, which will ...

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