|GDPR Supplier Review|
Select ‘Your Company’ to asses your company, this will enable you to display your score on the company awards page (if you have selected to display awards in your profile).
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|GDPR Supplier Compliance Rating|
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Level 1 - Initial
Very Low compliance to GDPR
Level 2 - Managed
Low compliance to GDPR
Level 3 - Defined
Good compliance to GDPR
Level 4 - Quality
High compliance to GDPR
Level 5 - Optimised
Very High Compliance to GDPR
|GDPR Supplier Review Questions||Compliance||Quality|
|Policy & Governance|
Yes - There is evidence that the supplier satisfies the requirement.
No - The supplier does not satify the requirement.
N/A - This requirement is not applicable to the supplier.
Red - Only verbal evidence is available to support this answer.
Amber - There is some documented evidence but it doesn't satisfy the requirement completely.
Green - There is documented evidence to support this answer.
N/A - This requirement is not applicable to the supplier.
|Do you have an individual assigned and accountable for data privacy (e.g. CPO (Chief Privacy Officer), Data protection Officer)?|
|Is there a group responsible for supporting and implementing policies, processes and procedures within the business?|
|Do you have a written policy in place that describes how personal data should be processed and managed?|
|Do you have a data retention policy?|
|Processes and Procedures|
|Do you have processes and procedures in place to support the 'Right to Erasure' removing/disposing of data safely?|
|Do you have processes and procedures in place for managing data privacy breaches?|
|Do you have a process/procedure to support a 'Right to Erasure' request?|
|Do you have a process/procedure to support the 'Subject Access Request'?|
|Do you have a procedure to disable user accounts to systems containing privacy data when a person leaves the organisation?|
|Do you have a process/procedure to remove suppliers access to systems containing privacy data when a when a suppliers contract has expired or terminated?|
|Do you have a process/procedure to assess prospective suppliers/sub-suppliers compliance to GDPR if they are providing Data Processing Services?|
|Do you have a process/procedure to carry out a Data Protection Assessment when initiating new tools or processes?|
|Do you have processes/procedures which define how to provide and revoke logins/access to systems?|
|Do you have processes/procedures in place to apply the data retention policy?|
|Do you have processes/procedures in place to confirm personal data is only used for the intended purpose?|
|Do you control and log who has physical access to your data (i.e. paper records or Storage media)?|
|Do you control who has access to your buildings and have the ability to deny access to individuals?|
|Are there shared access area's where multiple clients have physical access to other clients data?|
|Where data is stored in physical documents, are they stored in an access controlled room/cabinet?|
|When documents contain privacy data are disposed of do you use appropriate secure means?|
|Are technical assets such has hard drives and components disposed of using appropriate secure means?|
|As a supplier do you have an asset register that is current and up to date (logging what personal data is being held in all of your systems)?|
|Does your asset register log 'information assets' as well as physical assets?|
|Application and Network Access|
|Do you use tools to protect your applications and network (e.g. Anti Virus software)?|
|Are your web and in-house applications scanned for vulnerabilities?|
|Do you retain system logs of user access to applications and networks for any prospective investigation purposes?|
|Do you undertake regular penetration tests for your application and Network undertake?|
|Do you have managed access controls for all application and Network (i.e. require password/logins)?|
|Is there a one to one relationship between passwords and users (i.e. you don’t have common logins for more than one person)?|
|Has your system architecture been designed so there are logic and physical separations where required?|
|Does a third party have access to your network?|
|Do you prevent users from installing their own/chosen software?|
|Are security patches applied to applications and hardware in a timely manner?|
|Do you use firewalls to protect your network?|
|Is your Web site protected and logically separate from personal data?|
|Is there a record of what personal data is being transferred outside of the organisation and whom?|
|Do you retain a record of all suppliers who undertake Data Processing activities on your behalf?|
|Does your data contain 'unique traceable data' to enable you to identify where a breach occurred?|
|As a supplier are all individuals who process data on behalf of you within the EU?|
|Do you have the facility to encrypt data when it is being transferred to external systems, clients or suppliers?|
|Does your data exclude 'Special category data' (i.e. you don not hold medical data, ethnic origin)?|
|Are users within your company prevented from exporting personal data from all systems and databases unless they have specific permission?|
|Is personal data only kept within the EU and never transferred outside of the EU?|
|Are you able to demonstrate accurate logging and the use of Personal Data in line with your Data Retention Policy?|
|Do you operate a company wide Risk Management system and review on a regular basis?|
|Are all your policies and procedures reviewed at least annually to ensure they still meet the GDPR requirements?|
|Is there a log maintained of data privacy breaches?|
|Do you have Firewalls in place that implement Intruder Detection and Intruder Prevention systems to protect your network?|
|Do you enforce password changes at a regular interval?|
|Do you enforce password strength and complexity?|
|Do you prevent re-use of old passwords?|
|Are systems locked after multiple incorrect attempts?|
|Is your wireless network logically separated from accessing privacy data?|
|Do you comply with or have certification to any approved Information Security Standards (e.g. ISO27001, Cyber Essentials, NIST)?|
|If you process Credit Card payments are you compliant with PCI/DSS?|
|Do your contracts with third parties describe how personal data will be managed, kept secured and comply with GDPR?|
|Are there suitable penalties within your contracts to ensure/encourage compliance?|
|Are there suitable reviews and reports to demonstrate compliance described within your contract (when and how)?|
|Where applicable, does your website have a Privacy Statement and is it compliant with the GDPR?|
|Does you contract describe service requests to support GDPR (i.e. remove data, update date, produce reports, service information requests)?|
|Do all staff undertake appropriate training on data privacy on a regular basis?|
|Do all project staff undertake appropriate training to enable data privacy to be designed into projects?|
|When providing access to systems/data are users made aware of the importance of the data and how to avoid breaking GDPR?|
|Do you provide warning and reminders related to data when users log in?|
|Is there an on boarding training for GDPR for new employees before they are granted access?|