Now that you have finally got something going qua GDPR compliance – way short of what you’d want but still, at least something, better than the Nothing to which you were limited so far – there is a new twist to the requirements…
To be clear; by now you should at least have the requirements clear, and also possibly have some upsides lined up (if not, go shop with some vendor consultancy (and others); they’ll tell you about the benefits of data minimisation, the unstress of having your house on order, etc.). And have something going qua reconnaissance, though not armed recce or recattack.
But now, you may have to rethink. A bit. About what you’d have to have prepared when you land in M&A territory, or even in Chapter 7/11/13- (and 9-!) or any glocal receivership. Because … well, the idea sprang from this thing with de-anonymising data from sperm banks (in NL); until now most highly classified secrets (qua donorship). Turns out that not all clinics have the old data, still, because previously the secret was to be eternal hence best secured by throwing away the data.
But more seriously, not all clinincs exist anymore and there is no way to know where the data went, if anywhere.
And that’s where you organisation comes in. Not qua LoB but qua existence, now and in the future. Will you buy, take over, integrate some other org, or be on the receiving (uh…) end of the turmoil? You may want to make sure that the “GDPR” record of the other party is impeccable… Or end up with a mixed compliance bag which is equal to no compliance…
Possibly, you may have to prepare for some form of end-of-organisational-life where there is no body to take over your data and you might have to prepare for that ..?
Well, we’ll see what WG29 comes up with. At least, it will be additional stuff.
[In a weird twist of interpretation, this complex of buildings could have housed a private bank of said kind…; Sevilla BTW]