Download our free guide: Information Assets, the Foundation of Data Protection Compliance

Most data protection officers can’t answer a simple question: where does our organisation’s data actually live? This guide walks through why information asset management sits at the foundation of every other compliance activity — from your Record of Processing Activities to breach response and regulatory reporting — and what it takes to build an asset inventory that stays accurate instead of becoming another abandoned spreadsheet.

Fill in the form below to get your copy. For the full article version of this guide, see Information Asset Management: Why It’s Critical for Data Protection Compliance.

 

What Is Information Asset Management? Definition and Core Importance

Information asset management is the process of identifying, documenting, tracking, and maintaining all data and information systems within an organisation. It creates a centralised inventory of where data exists, who accesses it, and how it flows through systems.

Effective asset management requires more than spreadsheets. It demands systematic processes, consistent terminology, and ongoing maintenance to ensure accuracy.

Most organisations lack a complete picture of their information assets. When data protection officers speak with teams across NHS trusts, healthcare providers, higher education institutions, and mid-market organisations, a consistent gap emerges. Teams cannot answer this fundamental question: where does our data actually live?

This knowledge gap isn’t a documentation problem. It’s a compliance vulnerability that affects breach response, incident investigation, and regulatory accountability.

Asset management sits at the intersection of operational reality and regulatory requirement. It remains chronically underfunded, under-resourced, and misunderstood despite being foundational to all compliance efforts.


Why Do Organisations Struggle to Track Information Assets?

The modern data environment has become exponentially more complex. Cloud storage platforms multiply data copies. Software-as-a-Service applications introduce new data flows. Legacy systems retain historical information. Third-party integrations create interdependencies. Departmental shadow IT creates invisible data repositories.

Organisations accumulate data at unprecedented velocity, yet most treat asset management as documentation rather than operational necessity.

Key challenges organisations face:

    • Spreadsheets scattered across departments with conflicting information
    • Databases owned by individuals rather than departments
    • Systems retired but data copies remaining in backups
    • Shadow IT applications unknown to compliance teams
    • Inconsistent naming conventions across business units
    • Difficulty identifying duplicate asset records

When breach incidents occur or data subject access requests are raised, organisations discover these gaps immediately. Response teams cannot quickly answer: Which departments stored affected data? How many copies exist? Who has access? When was data scheduled for deletion?

    Without rapid answers, organisations cannot respond effectively to regulators or data subjects.


        How Does Asset Management Impact Data Protection Officer Responsibilities?

          Data Protection Officers operate under intense pressure. They hold accountability for compliance across entire organisations yet typically lead teams of one, two, or three people. This ratio creates an untenable situation where DPOs must understand operational reality across departments they don’t manage.

            The DPO dilemma:

              Without asset clarity, DPOs become reactive firefighters addressing immediate crises rather than proactive stewards building compliance infrastructure.

                With asset management, DPOs shift from chaos to control. They move from sending emails chasing spreadsheets to accessing centralised asset inventories. They shift from improvised responses to systematic processes.

                  Information asset management enables DPOs to delegate appropriately. Rather than being the single person holding all compliance knowledge, DPOs can empower Information Asset Managers and departmental teams to maintain data ownership. This transforms the DPO’s role from operational execution to governance and oversight.

                    Real example: One of our NHS ICB clients successfully implemented this model. By establishing clear asset ownership across departments and centralising information within a structured platform, they reduced DPO maintenance burden whilst improving accuracy. Teams became invested in documentation because they retained operational control.

                      This approach doesn’t work in isolation. It requires integration across the entire compliance programme.


                          What Regulatory Frameworks Require Information Asset Management?

                            Multiple regulatory frameworks now explicitly mandate asset management. Understanding these requirements clarifies why this practice has become essential.

                                • GDPR Requirements: The EU General Data Protection Regulation requires organisations to keep records of processing activities. These records only function as compliance evidence when connected to operational reality. If your Record of Processing Activities doesn’t reflect where data actually exists, it becomes a liability rather than a protection.
                                • UK Data Protection Act 2018: The UK’s data protection legislation includes similar documentation requirements. Organisations must demonstrate systematic knowledge of their information assets.
                                • ISO 27001 Information Security Standard: This framework explicitly requires asset inventories as a foundational security control. Organisations cannot manage what they don’t track.
                                • NIST Cybersecurity Framework 2.0: The National Institute of Standards and Technology’s framework emphasises asset management as essential infrastructure.

                            These frameworks exist because organisations that lose control of information assets simultaneously lose control of their security and compliance posture.

                              Practical scenario: An organisation collects customer data through a web form. Data flows into a CRM system. The CRM syncs to an email marketing platform. The marketing platform retains backups for 90 days post-deletion. An employee exports records to a personal folder. Without asset mapping, the organisation cannot accurately describe processing activities, assess risks, or respond confidently to data subject rights requests.

                                Third-party risk management also depends on asset clarity. When organisations transfer processing to vendors or share data with partners, they must understand what assets are involved. Without this clarity, vendor assessments become guesswork.


                                    Manual Spreadsheets vs. Centralised Asset Management: A Comparison

                                      Aspect Spreadsheets Centralised Management
                                      Data Accuracy Frequently outdated within weeks Consistently current with RoPA updates
                                      Duplicate Detection Manual review, high error rate Automated consolidation with system rules
                                      Access Control Limited, version control problems Role-based access with audit trails
                                      Reporting Capability Static reports requiring manual compilation Real-time dashboards and automated exports
                                      Integration Disconnected from compliance workflows Connected to risk management, ROPA, incident response and Data Management Frameworks
                                      Scalability Becomes unmanageable above 200 assets Handles thousands of assets efficiently
                                      Compliance Evidence Difficult to demonstrate systematic approach Clear audit trail of governance activities
                                      Team Efficiency DPO handles 80% of asset work DPO handles 20%, teams maintain own assets

                                          What Are the Practical Barriers to Implementing Asset Management?

                                            Organisations consistently encounter predictable obstacles when establishing asset management programmes.

                                                  • Initial Mapping Burden: Organisations lack systematic ways to inventory assets across departments. Sending requests to dozens of departments generates hundreds of inconsistent responses. Many are duplicative. Many are incomplete. Data quality suffers before reaching the DPO.
                                                  • Information Staleness: Systems change rapidly. Applications get updated or retired. Data flows shift. Without efficient maintenance mechanisms, organisations quickly return to fragmented states.
                                                  • Integration Gaps: Asset inventories stored separately from Risk Registers and Records of Processing Activities create friction. Teams avoid tools that complicate their work.
                                                  • Consolidation Complexity: When multiple teams submit asset information, someone must identify duplicates, standardise terminology, and maintain single versions of truth. This tedious work remains essential.
                                                  • Resource Constraints: Lean data protection teams lack capacity for ongoing maintenance.
                                                  • Resistance to Change: Teams accustomed to departmental independence resist centralised documentation.

                                            These barriers explain why many organisations have abandoned asset management initiatives. Overcoming them requires systematic approaches and appropriate technology.


                                                How Does ProvePrivacy Solve Information Asset Management Challenges?

                                                  Information asset management shouldn’t exist in isolation. It must integrate within a broader data protection platform connecting asset information to risk assessment, compliance workflows, and stakeholder reporting.

                                                    The ProvePrivacy platform includes an integrated Information Asset Module designed specifically to address these operational barriers. It is populated from the RoPA meaning there is no separate management task. Rather than creating another disconnected documentation tool, the module functions within a collaborative ecosystem.

                                                      ProvePrivacy’s approach:

                                                              • Information Asset Managers consolidate duplicate records automatically
                                                              • Teams maintain current information through intuitive workflows
                                                              • Record of Processing Activities feeds directly into the Information Asset Register
                                                              • Risk assessment integrates with asset information
                                                              • Incident response workflows can access centralised asset data
                                                              • Senior stakeholders access real-time asset dashboards

                                                      Asset information becomes part of a single source of truth. DPOs and teams rely on this centralised inventory to demonstrate compliance effectively.

                                                        The platform prioritises simplicity over complexity. Teams without deep technical backgrounds contribute asset information through straightforward workflows. The system handles consolidation and ensures consistency automatically.

                                                          ProvePrivacy’s collaborative model empowers operational teams to maintain ownership of their information whilst giving compliance teams visibility and control. This shifts asset management from compliance department responsibility to organisation-wide accountability.

                                                            This integration transforms asset management from a documentation exercise into operational infrastructure supporting all compliance activities.


                                                                Key Implementation Steps for Information Asset Management Success

                                                                  Implementing effective asset management requires deliberate planning and systematic execution.

                                                                    Step One: Current State Assessment

                                                                    Begin by understanding what you currently know and don’t know about your organisation’s information assets (your RoPA should be a great place to start). Conduct a rapid discovery process. Identify major data repositories. Map existing documentation across departments.

                                                                    Step Two: Stakeholder Engagement

                                                                    Engage information asset owners across departments. Establish clear roles and responsibilities. Ensure teams understand why asset management matters to their operations.

                                                                    Step Three: Baseline Establishment

                                                                    Work with key departments to establish baseline asset records. Focus initially on high-risk data categories. Use templates to ensure consistency.

                                                                    Step Four: Systematic Processes

                                                                    Implement processes for ongoing maintenance. Define how asset information gets updated when systems change. Establish review cycles. Create clear deprecation procedures.

                                                                    Step Five: Platform Integration

                                                                    Integrate asset information with your existing compliance programme rather than creating isolated documentation. Connect asset data to your Risk Register. Link it to your Record of Processing Activities. Use asset information in incident response workflows.

                                                                    Organisations that prioritise these steps build compliance foundations deliberately. They treat asset management as operational infrastructure rather than compliance documentation.


                                                                    Frequently Asked Questions About Information Asset Management

                                                                    Q: How many information assets does a typical organisation have?

                                                                    A: This varies significantly. Small organisations may have 50-100 assets. Mid-market organisations typically have 200-500. Large enterprises often manage thousands. Asset count reflects business complexity and data management maturity.

                                                                    Q: How often should asset information be updated?

                                                                    A: Asset records should be reviewed and updated minimally annually. High-risk assets should be reviewed quarterly. When significant system changes occur, updates should happen immediately.

                                                                    Q: Who should own information assets?

                                                                    A: Business departments should own assets they use operationally. Information Asset Managers within IT or governance should coordinate and consolidate. Data Protection Officers provide oversight without daily operational responsibility.

                                                                    Q: Can existing CMDB (Configuration Management Database) systems serve as asset inventories?

                                                                    A: CMDBs and information asset inventories serve different purposes. CMDBs focus on technical specifications and dependencies. Asset management focuses on data, ownership, and compliance. Many organisations use both systems together.

                                                                    Q: How does asset management support incident response?

                                                                    A: During breach incidents, asset data enables rapid identification of affected systems, data categories, access logs, and individuals to notify. This accelerates investigation and regulatory notification.

                                                                    Want a copy of this guide to work through offline, or to hear practitioners debate these challenges directly? Download the companion guide, watch our webinar recording on managing data assets, or read the five key takeaways on IAR, RoPA and stakeholder buy-in from the DPN panel discussion.


                                                                    Sources and Authority References

                                                                     

                                                                    In a recent survey we conducted, 48% of respondents identified data retention and deletion policies as one of the biggest data compliance challenges they currently face. While this may suggest uncertainty around policy design, the reality for many organisations is different.

                                                                    Most organisations already have retention and deletion policies in place. The real challenge lies in ensuring those policies are supported by clear, repeatable processes that make them effective in practice.

                                                                    Under regulations such as the GDPR, organisations are required not only to define how long personal data is retained, but to ensure it is deleted when it is no longer necessary. Having a policy alone is not sufficient — organisations must be able to demonstrate how that policy is implemented and enforced.

                                                                    Policy vs Process: An Important Distinction

                                                                    • A retention policy sets out what should happen and why.
                                                                    • A process or procedure explains how it actually happens.

                                                                    Without documented procedures, retention policies risk becoming theoretical. This gap often emerges during audits, regulatory enquiries, or data subject access requests, when organisations are asked to evidence how data is deleted in line with stated timeframes.

                                                                    A Common Example: Email Retention

                                                                    Email is one of the most common areas where policy and process diverge.

                                                                    An organisation may have a policy stating that emails are deleted after six months. However, key operational questions are often left unanswered:

                                                                    • Is there an automated deletion schedule in place?
                                                                    • Does it apply to archived emails, shared mailboxes, and backups?
                                                                    • Who owns and reviews the retention settings?
                                                                    • How are legal holds managed and lifted?
                                                                    • Is deletion logged and auditable?

                                                                    Without a defined process, emails may be retained indefinitely, increasing both compliance risk and data exposure.

                                                                    Why Process Matters for GDPR Compliance

                                                                    The GDPR places emphasis on accountability and demonstrability. Organisations must be able to show that retention limits are enforced consistently across systems and data types.

                                                                    This requires:

                                                                    • Clear ownership of retention and deletion activities
                                                                    • Technical controls aligned to policy
                                                                    • Documented procedures for exceptions such as legal holds
                                                                    • Evidence that deletion actions are carried out as intended

                                                                    Where these elements are missing, organisations may believe they are compliant while unknowingly retaining personal data beyond permitted periods.

                                                                    Moving Beyond Policy-Only Compliance

                                                                    The survey results highlight that retention and deletion remain challenging not because policies are absent, but because execution is complex, but it doesn’t need to be.

                                                                    Effective data retention compliance requires policy and process to work together. Policies define intent, but procedures, systems, and accountability are what turn that intent into consistent, defensible practice.

                                                                    For organisations looking to strengthen their GDPR compliance posture, the focus should be not just on what the policy says — but on how it is carried out, monitored, and evidenced every day.

                                                                    The ProvePrivacy platform has been developed to provide key features to help organisations manage, monitor and evidence data protection compliance. This includes a retention schedule to help manage the process of data retention. Book a demo to see the ProvePrivacy platform in action.

                                                                     

                                                                    Download our free guide

                                                                     Avoiding the Common Pitfalls of Data Sharing Risks

                                                                    In our interconnected world, data sharing is crucial for business operations and personal interactions. Whether sharing customer information, collaborating with partners, or using cloud services, data is always on the move. However, this convenience comes with the responsibility to ensure data is shared securely and responsibly.

                                                                    In data protection terms there are two considerations which need to be addressed:

                                                                    1. Whether there are adequate legal safeguards in place to allow the transfer to take place

                                                                    2. Whether there are adequate organisational and technical measures in place to protect the data being shared 

                                                                    In this FREE downloadable guide we look at both of these considerations, starting with the first and how we can lawfully share personal data. 

                                                                    Why use ProvePrivacy to manage personal data and privacy risks?

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                                                                    This article has been merged into our fuller guide, Avoiding the Common Pitfalls of Data Sharing Risks: Legal and Technical Safeguards, which now covers both the legal safeguards and the practical, technical pitfalls in one place. Please update any bookmarks or links to point there.

                                                                    In our interconnected world, data sharing is crucial for business operations and personal interactions. When considering the pitfalls of data sharing, it is important to be aware of the responsibilities involved. Whether sharing customer information, collaborating with partners, or using cloud services, data is always on the move. However, this convenience comes with the responsibility to ensure data is shared securely and responsibly.

                                                                    In data protection terms there are two considerations which need to be addressed:

                                                                    1. Whether there are adequate legal safeguards in place to allow the transfer to take place; and
                                                                    2. Whether there are adequate organisational and technical measures in place to protect the data being shared

                                                                    This article covers both: the legal safeguards that need to be in place before personal data changes hands, and the practical, technical pitfalls that most commonly catch organisations out once the data is actually moving.


                                                                    Legal Safeguards for Sharing Personal Data

                                                                    Data Processors

                                                                    Article 28 of the GDPR requires data controllers to use processors who provide sufficient guarantees to protect personal data. These guarantees must be included in a binding contract with specific clauses outlined by the GDPR.

                                                                    Unlike ‘Standard Data Protection Clauses,’ (see International Transfers below) the wording of these clauses is not mandated and can vary, making verification difficult. Using a checklist and seeking legal help is advisable.

                                                                    These clauses ensure appropriate technical and organizational measures are in place to meet GDPR requirements and protect data subjects’ rights. The contract ensures the processor acts only on the controller’s instructions, maintains confidentiality, implements security measures, and obtains consent for sub-processing.

                                                                    A Data Processing Agreement (DPA) must also be in place, specifying the nature, purpose, types of personal data, and duration of the processing. The DPA can be part of the contract, usually as a schedule.

                                                                    Joint Data Controllers

                                                                    Joint Data Processors are explicitly mentioned in the regulation, requiring a Data Sharing Agreement (DSA).

                                                                    Joint Controllers are two controllers using the same data for similar purposes, such as two organizations sharing data collected at a trade show for marketing. This might confuse data subjects about who controls their data or handles complaints.

                                                                    A DSA sets the terms of data sharing, ensuring transparency and cooperation between parties when a data subject makes a request. It also puts safeguards in place to protect data subjects. A DSA is required under Article 29 of the GDPR and must not be omitted.

                                                                    Data Controllers

                                                                    Data protection between Data Controllers is usually covered in a contract. For example, an organization engaging a pension provider should address data protection concerns in their contract. Since both parties control the data for their own purposes, these clauses are typically limited and not mandated by regulation. However, having a sharing agreement is good practice.

                                                                    Data protection regulation requires ‘Accountability,’ so documenting and recording assessments is crucial for compliance. A solution like ProvePrivacy can help with this.

                                                                    International Data Sharing

                                                                    To share personal data internationally, additional safeguards are needed. These vary depending on whether the destination is an “Adequate Country” or a “Third Country.”

                                                                    Adequate Countries

                                                                    An “adequate country” is a non-EU country that the European Commission has determined provides data protection equivalent to the EU. This is decided through an adequacy decision, assessing the country’s data protection laws, enforcement, and commitments.

                                                                    Countries with an adequacy decision include Andorra, Argentina, Canada (commercial organizations), Faroe Islands, Guernsey, Israel, Isle of Man, Japan, Jersey, New Zealand, Republic of Korea, Switzerland, the UK, and Uruguay. This list can change and is available here.

                                                                    Data transfers to these countries can occur without additional safeguards, similar to within the EU.

                                                                    Third Countries

                                                                    A “third country” is any country outside the European Economic Area (EEA), which includes EU member states, Iceland, Liechtenstein, and Norway. When transferring personal data to a third country, special rules and safeguards must ensure data protection.

                                                                    An adequacy decision by the European Commission confirms that a third country provides comparable data protection to the EU, allowing transfers without additional safeguards. If no adequacy decision exists, appropriate safeguards like Standard Contractual Clauses (SCCs) or Binding Corporate Rules (BCRs) must be in place. These pre-approved clauses cannot be altered, or they become invalid.

                                                                    Other safeguards, such as codes of conduct, are less common. If no safeguards exist, data transfers may still be possible with consent from data subjects or limited approval from the regulator for one-off transfers with a compelling legitimate interest.

                                                                    Regular audits and assessments should ensure ongoing compliance and address potential risks associated with data sharing.

                                                                    United States

                                                                    The United States is not an ‘adequate country,’ but the EU-U.S. Data Privacy Framework (DPF) provides a level of assurance at the organizational level. This framework, developed by the U.S. Department of Commerce and the European Commission, allows U.S. organizations to self-certify their adherence to privacy principles, ensuring EU data subjects’ rights are protected. The UK has adopted this framework for its own purposes.

                                                                    Data Protection Professionals should remain vigilant about changes to this framework, as it is considered by some to be on thin ice. Legal scrutiny and potential invalidation, similar to the EU-U.S. Privacy Shield’s fate in the Schrems II decision, could jeopardise the framework’s validity and disrupt data transfers. Concerns about U.S. government surveillance and the adequacy of privacy protections for UK data subjects remain contentious issues.


                                                                    Common Pitfalls to Avoid When Sharing Data

                                                                    Getting the legal safeguards right is only half the job. Many organisations and individuals fall into the same avoidable traps once data is actually moving. Here’s what to watch for, and how to avoid it.

                                                                    1. Lack of Data Encryption

                                                                    One of the most critical mistakes organisations make when sharing data is failing to encrypt it properly. Encryption ensures that even if data is intercepted, it cannot be accessed without the decryption key. Without encryption, sensitive data is vulnerable to cyberattacks, unauthorised access, and data breaches.

                                                                    How to avoid it:

                                                                    • Always use end-to-end encryption for data transfers.
                                                                    • Use secure methods such as HTTPS or SFTP to ensure the integrity of the data during transit.
                                                                    • For stored data, employ encryption protocols like AES (Advanced Encryption Standard) to protect it at rest.

                                                                    2. Failure to Define Access Permissions

                                                                    When sharing data with third parties, organisations often fail to clearly define who can access specific pieces of information. This opens the door for data to be misused, either accidentally or intentionally. Sometimes, too many people or systems are given access to sensitive information, creating unnecessary risks.

                                                                    How to avoid it:

                                                                    • Implement strict access controls based on the principle of least privilege (POLP). Only give access to individuals who absolutely need it to perform their duties.
                                                                    • Regularly review and update access permissions to ensure that outdated or unnecessary access is revoked.
                                                                    • Use role-based access control (RBAC) systems to define and restrict access levels based on roles.

                                                                    3. Not Auditing Data Sharing Practices

                                                                    Data sharing is not a “set it and forget it” practice. Organisations should regularly audit how and with whom their data is being shared. This includes tracking data flow, checking who has access to what data, and identifying potential vulnerabilities. Without regular audits, it’s easy for risky behaviours or unauthorised access to go unnoticed.

                                                                    How to avoid it:

                                                                    • Set up automated logging and monitoring tools that track data access and sharing activities.
                                                                    • Perform periodic audits to ensure compliance with internal policies and external regulations like GDPR, CCPA, or HIPAA.
                                                                    • Address any anomalies or gaps in your audit logs immediately.

                                                                    4. Neglecting Legal and Compliance Obligations

                                                                    Different countries and industries have varying legal frameworks surrounding data privacy and sharing. Neglecting to account for these laws can lead to costly fines, lawsuits, and reputational damage. Regulations like GDPR in the EU mandate how data should be handled, shared, and protected.

                                                                    How to avoid it:

                                                                    • Familiarise yourself with the relevant data protection laws in your jurisdiction and industry.
                                                                    • Ensure that any third parties you share data with are also compliant with applicable regulations.
                                                                    • If sharing data across borders, ensure that international data transfer agreements, like the Standard Contractual Clauses (SCCs) under GDPR, are in place.

                                                                    5. Over Reliance on Third-Party Providers

                                                                    While third-party services like cloud providers or data processors can offer convenience and scalability, relying too heavily on them can expose you to risks. A third-party vendor may not implement the same level of security protocols, or worse, they may be a target for cybercriminals. Data breaches that occur within third-party systems can directly affect your organisation.

                                                                    How to avoid it:

                                                                    • Perform due diligence before choosing any third-party vendor. Ensure that they follow industry best practices for data security and have a clear data protection policy.
                                                                    • Regularly review the security measures and compliance status of any third-party service providers.
                                                                    • Consider a contract that outlines data protection obligations, breach notifications, and audit rights.

                                                                    6. Inadequate User Education and Training

                                                                    A significant portion of data breaches stems from human error, whether it’s employees falling for phishing attacks, improperly handling data, or mistakenly sharing information with unauthorised parties. The best technology won’t be effective if the people using it aren’t properly trained.

                                                                    How to avoid it:

                                                                    • Implement a continuous education programme that trains employees on data security best practices, phishing awareness, and proper data handling procedures.
                                                                    • Run regular security drills and simulated phishing attacks to test employee readiness.
                                                                    • Make data privacy and security a core component of your organisation’s culture.

                                                                    7. Ignoring the Risks of Shadow IT

                                                                    Shadow IT refers to the use of unauthorised devices, applications, or services to store or share data, often without the knowledge or approval of IT departments. It’s an increasing issue in modern workplaces, where employees may bypass official tools to streamline their work or avoid red tape. Unfortunately, shadow IT can create significant vulnerabilities, especially when sensitive data is involved.

                                                                    How to avoid it:

                                                                    • Implement a clear and easy-to-follow data-sharing policy that encourages employees to use approved tools and systems.
                                                                    • Use software that detects and flags unapproved applications or cloud services being used on your network.
                                                                    • Educate employees on the risks of shadow IT and the importance of compliance with company data policies.

                                                                    8. Over-Sharing or Under-Sharing Data

                                                                    Another common pitfall is sharing too much or too little data. Over-sharing can lead to privacy violations, regulatory breaches, and unintended exposure of sensitive information. On the other hand, under-sharing can create operational inefficiencies and may hinder collaboration.

                                                                    How to avoid it:

                                                                    • Assess the needs of the recipient and share only the data necessary for the task or project at hand.
                                                                    • Use data masking or anonymisation techniques when sharing sensitive information that doesn’t require full disclosure.
                                                                    • Communicate clearly with recipients about the data being shared and any limitations or restrictions associated with its use.

                                                                    Conclusion: Prioritise Security, Responsibility and Awareness

                                                                    Data sharing is essential, but it comes with the responsibility to ensure lawful and responsible handling. Legal safeguards and technical measures are both crucial, and neither is sufficient on its own.

                                                                    For data processors, Article 28 of the GDPR mandates binding contracts with specific clauses to protect personal data. Joint Data Controllers require a Data Sharing Agreement (DSA) to ensure transparency and cooperation, and international transfers need safeguards that vary by destination, from adequacy decisions to Standard Contractual Clauses.

                                                                    Alongside those legal foundations, the day-to-day practical habits matter just as much: encrypting data in transit and at rest, defining and reviewing access permissions, auditing data flows, vetting third-party providers, training staff, and controlling shadow IT all reduce the risk of a data breach or privacy violation.

                                                                    Ultimately, protecting shared data is not just a technical or legal challenge but a cultural one. Ensuring that everyone involved, from employees to third-party vendors, understands the risks and responsibilities is key to safeguarding sensitive information in an increasingly complex data landscape.

                                                                    Want this as a reference you can share internally? Download our free guide to avoiding data sharing risks, or get in touch to see how the ProvePrivacy platform can help you manage data sharing risk day to day.

                                                                    The protection of personal data is a significant element of any information security ecosystem, and adhering to standards like ISO 27701 can enhance this protection. If this ecosystem is neglected, it can have a significant impact that puts your organization at risk of increasingly malicious threats which present an increasing risk to your business.

                                                                    ISO 27701 is a global privacy standard, and it demonstrates the importance of improved personal data protection. Evidencing that your organisation can meet ISO 27701 certification will ensure you have in place the processes and controls to protect your personal data assets and manage the data protection risks posed to your organisation.

                                                                    Understanding ISO 27701?

                                                                    ISO 27701 is an extension to ISO 27001 which includes additional requirements, objectives and controls for your Privacy Information Management System (PIMS). The standard provides guidance to organisations on how to act on data protection and privacy and assist them in protecting personal data enabling them to achieve compliance with regulations such as GDPR or the UK Data Protection Act (2018).

                                                                    ISO 27701 allows an organisation to establish a set of objectives and set controls to meet these objectives, thereby evidencing that actions are being taken to protect personal data. When an organisation applies the standard and extends its objectives to cover privacy management, it shows stakeholders that it is taking the protection of personal data seriously. Under revised regulation such as GDPR, data protection by design is a legal requirement. However, many organisations find this difficult to evidence, which is where implementing ISO 27701 provides the guidance and evidence required to achieve compliance.

                                                                    Who should seek ISO 27701 certification?

                                                                    Any organisation that handles any form of personal data should be concerned about how it is protected. This means that ISO 27701 could be relevant to all businesses.  Where the risk to personal data is more acute, such as large volumes of personal data, sensitive personal data or, where a data breach would have a more serious impact (for example on an organisations reputation) then ISO 27701 would be increasingly important. 

                                                                    Aligning with a PIMS such as ProvePrivacy will help an organisation to apply and evidence the standard and to encourage continual improvement within their organisation.  It is often the case that senior management aren’t clear about what is expected from them regarding protecting personal data, so implementing ISO 27701 would be a clear advantage to them.

                                                                    Does having ISO 27701 make us GDPR Compliant?

                                                                    No, you should not expect any system to make you compliant with data protection regulations, because risks and issues can occur at any time. However, ISO 27701 sets objectives and establishes controls which will provide your organisation with an auditable management standard and enable you to build an organisation which is resilient to risks. In doing so you should be able to begin evidencing data protection by design and by default alongside the technical and organisational measures that your organisation has put in place to protect personal data. 

                                                                    What happens if an issue arises such as a data breach?

                                                                    ISO 27701 would help your organisation to put policies, procedures and processes in place which dictate the response and address crucial questions, for example who to contact. The ProvePrivacy platform will help further with this by allowing the policies and procedures to be distributed annually to all staff, evidencing that they have read and understood them and by providing staff with a Breach and Risk reporting system, which alerts the appropriate response teams within your organisation, enabling them to act quickly and report to the regulators appropriately.

                                                                    ProvePrivacy can be used without the ISO 27701 module with similar benefits, however, applying it provides more of a guarantee that you’ve implemented adequate processes.

                                                                    How do we encourage continual improvement?

                                                                    Continual improvement sits at the heart of both the ISO 27701 standard and the ProvePrivacy platform. The ISO 27701 module within ProvePrivacy is designed not only to evidence that objectives and controls are implemented, but it also provides automated reminders when a control is due to expire, so that appropriate teams can respond in a timely manner. This allows risks to be assessed, improvements to be applied and issues to be avoided.

                                                                    How does ISO 27701 align with ISO 27001?

                                                                    ISO 27701 has been developed to be integrated within an ISO 27001 ISMS. In practice if an organisation wishes to be ISO 27701 certified it must also achieve ISO 27001 certification. The design of ProvePrivacy, allows an organisation to set and establish the objectives and controls for ISO 27701 in isolation if required. ProvePrivacy supports ISO 27001 objectives and controls in addition to ISO 27701 and encourages organisations to undertake both. Obtaining certification for both reduces duplication and saves time and enables auditors to perform deeper audits, implementing ProvePrivacy simplifies audits as most of the evidence is maintained within the platform.

                                                                    How can we evidence we are managing our objectives?

                                                                    ISO 27001 and ISO 27701 provide the guidance to setting your objectives and establishing your controls and it is up to each organisation to determine which objectives and controls it wishes to implement. ProvePrivacy assists by letting you select your objectives and controls, stating why you have elected to exclude any, you can also use ProvePrivacy to plan the implementation of controls, store supporting evidence that your controls are in place and working, and provide reminders when controls need to be reviewed.

                                                                    Whilst ProvePrivacy cannot remove the work required to become ISO 27001 or ISO 27701 certified, it can certainly help an organisation achieve certification and assist in preparation for audits. Book a demo to see the platform in action.

                                                                    During the DPN webinar on 21st February panellists Mark Roebuck, Robert Bond, Louise Garrett-Cox and Simon Blanchard took on a host of topics and questions ranging from “what are data assets and IARs,” to “how do I see the value of a ROPA and gain stakeholder buy-in”. 

                                                                    Here we summarise 5 key takeaways from the event.

                                                                    1. What is an Information Asset Register (IAR) and who does it benefit?

                                                                    An IAR is a record of the information that your organisation is storing and using, covering a diverse range of items (electronic and physical) and systems such as CRM, email accounts, HR and backups. The IAR classifies each asset in terms of sensitivity, criticality, risk profile and vulnerabilities, as well as areas such as who has access to the data and data retention periods, all of which illustrate data compliance.

                                                                    An IAR benefits multiple roles across an organisation:

                                                                    • Data Protection – an IAR provides understanding of who accesses what data, where it is held, and how long it is retained allowing those in data protection to ensure it is being managed and protected in the required way.
                                                                    • Data Governance – although there is crossover with the above it also provides those in data governance with insight into back up processes and procedures, enabling them to manage SLAs with 3rd parties as needed.
                                                                    • Organisation – the wider organisation gains confidence that the required compliance levels are being met, and that they can access the right data they need to undertake activities. In addition, it provides suppliers, partners, staff and customers with confidence in how their data is handled and managed.
                                                                    • For a fuller breakdown of what good information asset management looks like in practice, see our guide, Information Asset Management: Why It’s Critical for Data Protection Compliance.

                                                                      2. What are data assets?

                                                                      ‘Data assets’ refer to the various types of data an organisation collects, manages and uses as part of its operations, this can encompass a wide range of information such as customer data, financial records, operational data, research data and more. It also covers both structured and unstructured data both of which need to be identified in the context of a data asset register. 

                                                                      Structured data tends to be highly organised, following a specific format, typically stored in databases or spreadsheets such as a CRM or financial records. Unstructured data doesn’t have a predefined format making it more challenging to organise than structured data, an example of this could be emails and documents.

                                                                      3. What is a Record of Processing Activities (ROPA) and what is it’s value?

                                                                      A ROPA may be a compliance requirement for some but it is a valuable tool to any organisation. It provides a central place that collates all processing activities in turn allowing organisations assess these for data protection risks and identify gaps for continuous improvements including:

                                                                      • Areas where risk mitigation is required
                                                                      • Compliance with privacy notices
                                                                      • Ensuring correct contracts/SLAs are in place
                                                                      • These continuous improvements then help build an overall organisation risk profile so that activities can be prioritised, progress monitored and compliance retained.

                                                                        4. How important is gaining & retaining stakeholder buy-in?

                                                                        Ensuring that stakeholders are actively involved in managing and updating a ROPA is key to its success and the overall management and mitigation of an organisation’s risk profile. Ways to gain and retain stakeholder buy in include:

                                                                        • Allocated data champions who take ownership of areas of the ROPA and educate others within their teams.
                                                                        • Central information page that shares regular updates and answers to FAQs.
                                                                        • Data champion workshops to encourage the sharing of lessons learnt and insights
                                                                        • Regular one to ones with data champions to help bring changes and updates to the fore.
                                                                        • If relationships are managed and maintained the overall importance and awareness of a ROPA is understood.

                                                                          5. What measures and controls can be put in place to mitigate risks?

                                                                          Measures and controls will vary depending on various factors including the type of risk, volume of data and sensitivity, as well as the organisation’s risk appetite. 

                                                                          A great place to start is to look at the information security, and security and data governance policies, these will cover areas such as MFA, restricted access, file sharing, staff training, procedures, and information privacy and retention. Once ready stakeholder management can then be sought to gain early buy-in to these policies and the importance of contents. 

                                                                          These are just some of the topics covered during the discussion, watch the full webinar recording.

                                                                          Want to understand more about IAR? Download our quick guide to IAR or get in touch to discuss this and other data compliance requirements.

                                                                    How to effectively manage data assets (Webinar recording)

                                                                    Unsure how to manage information assets and personal data within your organisation? In this webinar panellists covered a range of topics including:

                                                                    • What are data assets?
                                                                    • IARs
                                                                    • ROPAs
                                                                    • Stakeholder engagement

                                                                    Want the panel’s key points in writing? Read our 5 key takeaways on IAR, RoPA and stakeholder buy-in, or for a fuller guide to building and maintaining an information asset register, see Information Asset Management: Why It’s Critical for Data Protection Compliance.

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                                                                    As a business the task of safeguarding valuable assets has, and continues to become more challenging with technology and information continually evolving. Establishing and maintaining an Information Asset Register (IAR) is just one element of this safeguarding and provides a comprehensive inventory of an organisation’s data and information resources. This in turn enables better management, protection, and utilisation of these assets. 

                                                                     

                                                                    In this article, we will explore how an Information Asset Register can contribute to enhanced security, regulatory compliance, and overall operational efficiency.

                                                                     

                                                                    1. Identification and Classification

                                                                    An IAR starts by identifying and classifying the diverse variety of information assets within an organisation. This process involves categorising data based on its sensitivity, criticality, and relevance to business operations. By creating a detailed inventory, organisations gain a clearer understanding of the data they possess, allowing for targeted protective measures.

                                                                     

                                                                    2. Risk Management

                                                                    Understanding the risks associated with each information asset is vital for effective risk management. An IAR facilitates the assessment of potential threats and vulnerabilities, helping organisations prioritise resources and efforts to mitigate these risks. By categorising assets according to their importance, organisations can allocate security measures proportionately, ensuring that their most critical information receives the highest level of protection.

                                                                     

                                                                    3. Regulatory Compliance

                                                                    In an era of increasing data protection regulations, compliance is paramount. An IAR supports organisations in maintaining compliance with data protection laws and industry regulations. By documenting how information is collected, processed, and stored, organisations can demonstrate accountability and transparency to regulatory authorities. This proactive approach not only reduces the risk of legal consequences but also builds trust with customers and partners.

                                                                     

                                                                    4. Access Control and Authorisation

                                                                    Efficient management of information assets involves controlling who has access to what data. An IAR provides a foundation for implementing robust access control measures. By clearly documenting the individuals or roles authorised to access specific information assets, organisations can prevent unauthorised access, reducing the risk of data breaches and insider threats.

                                                                     

                                                                    5. Data Lifecycle Management

                                                                    Information assets have a lifecycle, from creation to archival or disposal. An IAR aids in managing this lifecycle effectively. By tracking when data is created, accessed, modified, and deleted, organisations can optimise storage resources, reduce clutter, and ensure compliance with data retention policies. This not only enhances efficiency but also streamlines compliance efforts.

                                                                     

                                                                    6. Incident Response and Recovery

                                                                    Despite the best preventive measures, security incidents can still occur. An IAR plays a crucial role in incident response and recovery. By having a clear record of information assets, organisations can quickly identify compromised data and take swift action to contain and recover from security breaches. This minimises the impact of incidents and aids in the restoration of normal business operations.

                                                                     

                                                                    7. Resource Optimisation

                                                                    An IAR is a valuable tool for optimising resources. By understanding the value and importance of each information asset, organisations can allocate resources more effectively. This includes investments in security measures, staff training, and technology solutions.

                                                                     

                                                                    An IAR is a cornerstone of modern information management and security practices. By providing a centralised inventory of information assets, organisations can enhance their security measures, achieve regulatory compliance, and optimise operational efficiency. With the digital landscape continuing to evolve, those businesses that prioritise the development and maintenance of a robust IAR will be best placed to navigate the challenges of an increasingly data-centric world.ProvePrivacy allows your organisation to demonstrate that it has the technical and organisational measures and reporting to support processes, with your ROPA directly connected to a live information asset register. Book a demo.

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