ICS ECDPO study materials
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ICS ECDPO key terms

ICS ECDPO · Get comfortable with the vocabulary.

Personal Data

Any information relating to an identified or identifiable natural person, such as a name, identification number, location data, or online identifier, whether held electronically or in paper files.

Related: Data Subject, Processing, Special Category Data
Data Subject

The living individual to whom personal data relates. Data subjects have enforceable rights over how their information is collected, used, stored, and shared by organizations.

Related: Personal Data, Data Subject Rights
Processing

Any operation performed on personal data, including collection, recording, organization, structuring, storage, adaptation, retrieval, consultation, use, disclosure, erasure, or destruction, whether automated or manual.

Related: Personal Data, Data Processing Agreement
Special Category Data

Personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data for identification, health data, or data concerning sex life or sexual orientation, requiring extra protection.

Related: Personal Data, Lawful Basis
Data Minimization

The principle that personal data collected must be adequate, relevant, and limited to what is necessary for the specified purpose, avoiding excessive or unrelated collection.

Related: Purpose Limitation, Storage Limitation
Purpose Limitation

The requirement that personal data be collected for specified, explicit, and legitimate purposes and not further processed in a manner incompatible with those purposes.

Related: Data Minimization, Storage Limitation
Storage Limitation

The principle that personal data should be kept in identifiable form only for as long as necessary for the purposes for which it is processed, with defined retention periods and secure deletion thereafter.

Related: Data Minimization, Purpose Limitation
Accountability Principle

The obligation on organizations to demonstrate compliance with data protection principles, including maintaining records, policies, training evidence, and the ability to prove appropriate measures are in place.

Related: Data Protection Officer, Record of Processing Activities
Lawful Basis

A legal ground that justifies processing personal data, such as consent, contract, legal obligation, vital interests, public task, or legitimate interests. At least one basis must apply before processing begins.

Related: Consent, Legitimate Interests
Consent

A freely given, specific, informed, and unambiguous indication of the data subject's wishes by which they agree to processing, given by a statement or clear affirmative action, and which can be withdrawn at any time.

Related: Lawful Basis, Withdrawal of Consent
Legitimate Interests

A lawful basis where processing is necessary for the legitimate interests of the controller or a third party, unless overridden by the rights and freedoms of the data subject, requiring a balancing assessment.

Related: Lawful Basis, Legitimate Interests Assessment
Legitimate Interests Assessment

A documented three-part test identifying the legitimate interest, showing processing is necessary, and balancing it against the individual's rights and expectations, used to justify processing under that basis.

Related: Legitimate Interests, Data Protection Impact Assessment
Withdrawal of Consent

The data subject's right to revoke previously given consent at any time. Withdrawal must be as easy as giving consent, and processing based on consent must stop once it is withdrawn.

Related: Consent, Data Subject Rights
Data Subject Rights

The set of entitlements individuals have over their personal data, including access, rectification, erasure, restriction, portability, objection, and rights related to automated decision-making.

Related: Subject Access Request, Right to Erasure
Subject Access Request

A request from an individual to obtain a copy of their personal data held by an organization, together with information about processing purposes, recipients, retention, and rights, typically answered within one month.

Related: Data Subject Rights, Identity Verification
Right to Erasure

Also called the right to be forgotten, it allows individuals to request deletion of their personal data where there is no compelling reason for continued processing, subject to legal exceptions.

Related: Data Subject Rights, Storage Limitation
Identity Verification

The process of confirming that a person making a data subject request is who they claim to be, using proportionate checks before disclosing or changing personal data.

Related: Subject Access Request, Data Subject Rights
Data Protection Impact Assessment

A structured risk assessment required before high-risk processing, identifying the nature of the processing, assessing necessity and risks to individuals, and documenting mitigation measures and safeguards.

Related: High-Risk Processing, Risk Assessment
High-Risk Processing

Processing likely to result in a high risk to individuals' rights and freedoms, such as large-scale special category data, systematic monitoring, or automated decision-making, which triggers a DPIA requirement.

Related: Data Protection Impact Assessment, Automated Decision-Making
Risk Assessment

The process of identifying, analyzing, and evaluating risks to individuals from data processing, considering likelihood and severity of harm, and determining appropriate controls to reduce risk.

Related: Data Protection Impact Assessment, Risk Mitigation
Risk Mitigation

Actions taken to reduce identified data protection risks to an acceptable level, such as technical safeguards, policy controls, training, or contractual restrictions, documented as part of risk management.

Related: Risk Assessment, Data Protection Impact Assessment
Automated Decision-Making

Decisions about individuals made solely by automated means without human involvement, including profiling, which may require safeguards such as human intervention or the right to contest the decision.

Related: High-Risk Processing, Data Subject Rights
Personal Data Breach

A security incident leading to accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to personal data, which may require notification to regulators and affected individuals.

Related: Breach Notification, Incident Response Plan
Breach Notification

The obligation to inform the supervisory authority of a personal data breach without undue delay, typically within 72 hours of awareness, and to notify affected individuals when the breach poses high risk.

Related: Personal Data Breach, Supervisory Authority
Incident Response Plan

A documented set of procedures for detecting, containing, investigating, and recovering from data security incidents, including roles, communication steps, and breach notification triggers.

Related: Personal Data Breach, Breach Notification
Encryption

A technical security measure that converts data into unreadable form unless decrypted with a key, protecting confidentiality and often reducing breach notification obligations when applied to affected data.

Related: Personal Data Breach, Pseudonymization
Pseudonymization

Processing personal data so it can no longer be attributed to a specific individual without additional information kept separately and protected, reducing risk while preserving some utility.

Related: Encryption, Anonymization
Anonymization

Irreversibly transforming personal data so that no individual can be identified by any means reasonably likely to be used, removing it from data protection law while requiring careful risk assessment.

Related: Pseudonymization, Personal Data
Data Protection Officer

An independent expert responsible for advising on compliance, monitoring data protection practices, providing training, and acting as contact point for regulators and data subjects, where appointment is required.

Related: Accountability Principle, Record of Processing Activities
Record of Processing Activities

A documented inventory describing processing purposes, categories of data and individuals, recipients, transfers, retention periods, and security measures, required as evidence of accountability.

Related: Accountability Principle, Data Protection Officer
Privacy by Design

The approach of embedding data protection safeguards into systems, processes, and products from the outset, rather than adding them after development, to reduce risk and support compliance.

Related: Data Protection Impact Assessment, Accountability Principle
Data Protection Training

Mandatory education for staff on handling personal data lawfully and securely, covering policies, breach reporting, subject rights, and role-specific risks, with completion records kept as accountability evidence.

Related: Accountability Principle, Incident Response Plan
International Data Transfer

Sending personal data to a country or international organization outside the originating jurisdiction, which requires a lawful transfer mechanism such as adequacy decision, standard contractual clauses, or binding corporate rules.

Related: Standard Contractual Clauses, Adequacy Decision
Standard Contractual Clauses

Pre-approved contractual terms used to safeguard personal data transferred to countries without an adequacy decision, imposing obligations on importers and exporters to protect the data.

Related: International Data Transfer, Adequacy Decision
Adequacy Decision

A formal determination by a supervisory authority that a third country provides an adequate level of data protection, allowing personal data to flow there without additional safeguards.

Related: International Data Transfer, Standard Contractual Clauses
Data Processing Agreement

A contract between a controller and processor setting out the processor's obligations, including processing only on instructions, security measures, sub-processor rules, assistance with rights, and deletion or return of data.

Related: Processor, Controller
Controller

The organization or entity that determines the purposes and means of processing personal data, bearing primary legal responsibility for compliance and for demonstrating accountability.

Related: Processor, Data Processing Agreement
Processor

An entity that processes personal data on behalf of and on the instructions of a controller, with contractual duties regarding security, confidentiality, sub-processing, and assistance with data subject rights.

Related: Controller, Data Processing Agreement
Sub-Processor

A third party engaged by a processor to carry out specific processing activities, requiring prior authorization from the controller and equivalent data protection obligations flowing down the chain.

Related: Processor, Data Processing Agreement
Supervisory Authority

An independent public body responsible for monitoring and enforcing data protection law, handling complaints, conducting investigations, and imposing corrective measures and fines.

Related: Breach Notification, Accountability Principle