Chapter 18 — Privacy and data protection: controls
Lesson map
Lesson 18 published. Map, example, EX052.
flowchart TD
N0["Learning outcomes"]
N1["18.1 Selecting controls"]
N2["18.2 Mapping"]
N3["18.3 Standards"]
N4["18.4 Tracking"]
N0 --> N1 --> N2 --> N3 --> N4
N4 --> EX["Worked example"]
EX --> Q["Exercise EX052"]
Logical drawing
flowchart LR
N0["Learning outcomes"]
N1["18.1 Selecting controls"]
N2["18.2 Mapping"]
N3["18.3 Standards"]
N4["18.4 Tracking"]
N0 --> N1 --> N2 --> N3 --> N4 --> Q["EX052"]
[Learning outcomes]
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v
[18.1 Selecting controls]
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v
[18.2 Mapping]
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v
[18.3 Standards]
|
v
[18.4 Tracking]
|
v
[Worked example] --> [Exercise EX052]
Learning outcomes
You will (1) select controls for Quayside's risks; (2) map controls to principles; (3) track implementation.
18.1 Selecting controls
Aisha lists controls: SDK review, access request checklist, CCTV deletion check, file scanning, multi-factor authentication and inactive account deletion. She chooses controls that respond to findings in earlier chapters rather than copying a generic list. Each control addresses a real failure: the ad SDK, the incomplete access response, the CCTV firmware reset, the forgotten files, weak manager logins and accounts kept forever. This makes the control set easy to explain, because every item has a story that staff remember. Generic controls with no story are deferred.
18.2 Mapping
She maps each to principles: SDK review to lawfulness and transparency, CCTV deletion to storage limitation, MFA to integrity and confidentiality. SDK review also supports purpose limitation, because it stops data flowing to new purposes. The access request checklist supports transparency and the right of access. File scanning supports storage limitation and confidentiality. Inactive account deletion supports storage limitation and minimisation. The map shows that accuracy has no dedicated control, so she adds a yearly reminder asking members to check their details.
18.3 Standards
She notes that ISO/IEC 27701 provides privacy controls extending an information security management system, and the NIST Privacy Framework organises privacy outcomes. Quayside uses them as reference. She does not attempt certification; she uses the documents as checklists to find missing areas. The NIST Privacy Framework functions, such as Identify-P and Control-P, help her group activities. ISO/IEC 27701 control lists remind her of training and supplier management. She records which reference items Quayside already meets and which are planned, so progress can be shown to the leadership team.
18.4 Tracking
Each control has an owner, status and evidence. Mr. Reilly notes that mapping shows coverage gaps. The tracker is a simple table shared with owners. Status values are planned, in progress, operating and tested. A control counts as tested only when evidence shows it worked, such as a log of deleted clips or a completed access request test. Aisha reviews the tracker monthly and asks owners to update evidence links, not just status words. Owners without evidence stay at in progress. Status alone proves nothing.
Worked example
Aisha lists six controls, maps them to GDPR principles, references ISO/IEC 27701 and the NIST Privacy Framework, and tracks owners and evidence.
Synthetic case. Controls are synthetic; ISO/IEC 27701 and NIST Privacy Framework are real.
Errors and limits
A mapped control is not necessarily effective.
Exercises
- EX052 — CCTV principle. Which principle does CCTV deletion support? Rubric: 3 = storage limitation;; 2 = partly correct;; 1 = other;; 0 = none.
- EX053 — Reference standard. Name one standard used as reference. Rubric: 3 = ISO/IEC 27701 or NIST Privacy Framework;; 2 = one;; 1 = vague;; 0 = none.
- EX054 — Mapping benefit. Why map controls to principles? Rubric: 3 = shows coverage gaps;; 2 = mentions gaps;; 1 = vague;; 0 = none.
Continue studying — lesson 18 (chapter 18 of 30)
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