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The Global Privacy Enforcement Network's (GPEN) annual intelligence gathering operation looked at how well organisations have implemented the core concepts of accountability into their own internal privacy policies and programmes.

The joint study, known as the 'GPEN sweep', is carried out by data protection regulators across the globe and this year looks at how they have taken responsibility for complying with data protection laws.

Whilst there were examples of good practice, it was found that a number of organisations had no processes in place to deal with the complaints and queries raised by data subjects, and were not equipped to handle data security incidents appropriately.

ICO Head of Intelligence, Adam Stevens, yesterday said:

“The findings suggest that whilst organisations contacted by the ICO and our international partners have a good understanding of the basic concept of accountability, in practice there is significant room for improvement.

“It is important that organisations have appropriate technical and organisational measures in place. This includes having clear data protection policies, taking a ‘data protection by design and default’ approach and continuing to review and monitor performance and adherence to data protection rules and regulations.”

Participating GPEN members made contact with 356 organisations in 18 countries during the ‘sweep’ and came to the following conclusions:

• When it comes to monitoring internal performance in relation to data protection standards, many organisations were found to fall short, with around a quarter who responded having no programmes in place to conduct self-assessments and/or internal audits.
• Organisations were generally found to be quite good at giving data protection training to staff, but often failed to provide refresher training to existing staff.
• The organisations that indicated that they have monitoring programmes in place generally gave examples of good practice, noting that they conduct annual audits or reviews and/or regular self-assessments.
• Nearly three quarters of organisations across all sectors and jurisdictions had appointed an individual or team who would assume responsibility for ensuring that their organisation complied with relevant data protection rules and regulations.
• Over half of the organisations surveyed indicated that they have documented incident response procedures, and that they maintain up to date records of all data security incidents and breaches. However, a number of organisations indicated that they have no processes in place to respond appropriately in the event of a data security incident.

In terms of national findings, the UK Information Commissioner’s Office (ICO) made contact with 28 organisations across various sectors in the UK, and came to the following conclusions:

•  Only 67% of organisations who provided a response said that they conduct regular self-assessments or audits of internal data protection standards and practices, and only 67% indicated that they maintain inventories of personal data held.
•  83% of UK organisations who responded to the ICO’s queries indicated that they have implemented an internal data privacy policy and ensure that staff receive data protection training.
• It was positive to note that 100% of organisations in the UK who provided a response indicated that they felt they had someone within the organisation at a sufficiently senior level responsible for privacy governance and management.

As a result of the investigation, individual GPEN members may contact organisations in their own countries to assess what remedial action they need to take to improve user controls over their personal information.

For further information contact the ICO Press Office on 0303 123 9070 or visit the media section of our website.

Editors’ notes

1. The Global Privacy Enforcement Network (GPEN) was established in 2010 upon recommendation by the Organisation for Economic Co-operation and Development. Its aim is to foster cross-border co-operation among privacy regulators in an increasingly global market in which commerce and consumer activity relies on the seamless flow of personal information across borders. Its members seek to work together to strengthen personal privacy protections in this global context. The informal network is comprised of over 60 privacy enforcement authorities in 39 jurisdictions around the world.
2. The GPEN Sweep is currently co-Chaired by the Information Commissioner Office, UK and the Office of the Privacy Commissioner, New Zealand.
3. For the exercise, participating GPEN member agencies were asked to reach out to organisations with a set of pre-determined questions which focused on these key elements of responsible data governance.
4. The Information Commissioner’s Office upholds information rights in the public interest, promoting openness by public bodies and data privacy for individuals.