Implementing Data Protection in Practice
From principles to controls
Implementation turns rules into everyday practice. Candidates should recognise the main organisational measures:
- Records of processing - a register of what data is held, why, and where.
- Privacy by design and by default - build protection into systems from the start.
- Data protection impact assessment (DPIA) - a risk review for high-risk processing (large-scale sensitive data, systematic monitoring).
- Data protection officer (DPO) - an independent adviser where required.
- Data breach handling - detect, contain, assess, and notify the regulator (and affected individuals where risk is high) within tight deadlines.
- Security measures - encryption, access control, staff training, and contracts with processors.
Traps
- Breach notification is not always to individuals - notify the regulator when required, and individuals only when there is high risk.
- A DPIA is not optional paperwork - it must precede high-risk processing.
- Processor contracts must impose obligations; a handshake is not enough.
- Training and access control are recurring exam answers for "what should the organisation do?" questions.
Worked example
A laptop holding customer records is stolen. Steps: contain and assess the risk; if personal data is exposed and risk is likely, notify the regulator within the deadline; if risk to individuals is high, inform them; record the incident. Rule of thumb: assess risk first, then decide who to notify - never stay silent.