Data protection is the process of safeguarding sensitive personal information from unauthorized access, use, disclosure, modification, or destruction. Data protection can help to ensure the privacy and security ofthe data subjects, and to comply with the legal and regulatory requirements that apply to the data processing activities1.
A highly regulated organization that acquired a medical technology startup company that processes sensitive personal information with weak data protection controls faces a high risk of data breaches, fines, lawsuits, reputational damage, or loss of customer trust. The best way for the acquiring company to reduce its risk while still enabling the flexibility needed by the startupcompany is to classify and protect the data according to the parent company’s internal standards, because it can help to:
Identify and categorize the sensitive personal information based on its value, sensitivity, and criticality, such as confidential, restricted, internal, or public
Apply and enforce the appropriate data protection policies, procedures, and controls for each data category, such as encryption, access control, backup, retention, or disposal
Align and integrate the data protection practices and processes of the startup company with those of the parent company, and ensure the consistency and compliance across the organization
Balance and optimize the trade-off between data protection and data usability, and allow the startup company to leverage the data for innovation and growth, as long as it meets the data protection standards of the parent company23
The other options are not the best ways for the acquiring company to reduce its risk while still enabling the flexibility needed by the startup company, but rather some of the steps or aspects of data protection. Identify previous data breaches using the startup company’s audit reports is a step that can help to assess the current data protection status and gaps of the startup company, and to learn from the past incidents and mistakes, but it does not address the future data protection needs and challenges of the startup company. Have the data privacy officer review the startup company’s data protection policies is an aspect that can help to ensure the legal and regulatory compliance of the data protection activities of the startup company, and to provide guidance and oversight for the data protection issues and risks, but it does not ensure the technical and operational effectiveness and efficiency of the data protection controls of the startup company. Implement a firewall and isolate the environment from the parent company’s network is a control that can help to prevent or limit the external or internal attacks or threats to the data of the startup company, and to reduce the exposure or impact of a data breach, but it does not ensure the availability or accessibility of the data for the legitimate and authorized purposes of the startup company. References =
Data Protection - ISACA
Data Classification - ISACA
Data Protection Best Practices - ISACA
[CRISC Review Manual, 7th Edition]
