Sherlocked Security – GDPR / CCPA Readiness
Ensuring Compliance with GDPR and CCPA for Data Protection and Privacy
1. Statement of Work (SOW)
Service Name: GDPR / CCPA Readiness
Client Type: Organizations that handle personal data of EU residents (GDPR) or California residents (CCPA)
Service Model: Privacy Compliance Assessment + Data Protection Impact Analysis + Remediation Recommendations
Compliance Coverage: GDPR (General Data Protection Regulation), CCPA (California Consumer Privacy Act)
Assessment Types:
- Data Mapping and Inventory (Personal Data Flow Analysis)
- Data Subject Rights Compliance (Access, Deletion, Portability)
- Consent Management Review (Collection and Documentation)
- Privacy Policy and Notices Review
- Third-Party Vendor Risk and Data Processing Agreement (DPA) Assessment
- Risk Assessment (Privacy Risks and Data Breaches)
2. Our Approach
[Scope Definition] → [Personal Data Inventory] → [Data Subject Rights Assessment] → [Consent and Policy Review] → [Third-Party Data Processor Assessment] → [Security Controls & Breach Response Evaluation] → [Compliance Report & Recommendations]
3. Methodology
[Personal Data Mapping] → [Data Subject Rights & Access Procedures] → [Privacy Policy Review] → [Risk Assessment & DPA Review] → [Vulnerability Scanning] → [Data Breach Response Plan] → [Compliance Report & Remediation Plan]
4. Deliverables to the Client
- GDPR / CCPA Compliance Gap Analysis Report
- Personal Data Inventory and Flow Mapping
- Data Subject Rights Compliance Assessment
- Consent Management Process Review
- Privacy Policy and Notice Recommendations
- Vendor Risk and DPA Review
- Data Protection Impact Assessment (DPIA)
- Data Breach Response and Security Controls Recommendations
- Compliance Roadmap and Remediation Plan
5. What We Need from You (Client Requirements)
- Access to systems and databases where personal data is processed or stored
- Data processing records (data sources, storage, processing activities)
- Existing privacy policies, notices, and consent management procedures
- List of third-party vendors or data processors handling personal data
- Incident response and breach notification protocols
- Scope confirmation for the assessment, including the jurisdictions covered by GDPR/CCPA
6. Tools & Technology Stack
- Data Mapping Tools: OneTrust, TrustArc, DataGrail
- Vulnerability Scanning: Qualys, Tenable, Nessus
- Privacy Impact Assessment (PIA/DPIA) Tools: OneTrust, Nymity
- Consent Management Platforms: Cookiebot, TrustArc
- Security Information and Event Management (SIEM): Splunk, LogRhythm
- Data Encryption & Masking: Varonis, Symantec DLP, Digital Guardian
7. Engagement Lifecycle
1. Kickoff & Documentation Review → 2. Personal Data Inventory and Mapping → 3. Data Subject Rights Review → 4. Consent Management and Privacy Policy Review → 5. Third-Party Risk Assessment → 6. Security Controls & Breach Response Plan Review → 7. Gap Analysis & Remediation Recommendations → 8. Final Compliance Report & Certification Roadmap
8. Why Sherlocked Security?
| Feature | Sherlocked Advantage |
|---|---|
| In-depth GDPR / CCPA Expertise | Our team has deep expertise in privacy regulations and compliance strategies. |
| Comprehensive Personal Data Mapping | We provide thorough mapping of personal data flows and processing activities. |
| Risk Identification and Remediation | We identify privacy risks and provide actionable remediation recommendations. |
| Vendor and Third-Party Assessments | We ensure third-party vendors are compliant and secure in handling personal data. |
| Data Subject Rights Compliance | We ensure organizations comply with data subject rights such as access, deletion, and portability. |
9. Real-World Case Studies
Mismanagement of Consent Records (GDPR)
Issue: The organization failed to capture and maintain valid consent records for EU customers.
Impact: GDPR non-compliance due to lack of documentation for consent.
Fix: Implemented an automated consent management platform, ensuring that all consent records were logged and stored securely.
Data Breach and Lack of Breach Notification (CCPA)
Issue: The organization experienced a data breach but did not notify affected customers as required by CCPA.
Impact: Legal and reputational risks due to non-compliance with breach notification requirements.
Fix: Established a clear breach notification process, integrated automated breach detection tools, and trained staff to comply with CCPA requirements.
10. SOP – Standard Operating Procedure
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Scope Determination
- Define the personal data processing activities covered by GDPR/CCPA.
- Identify all jurisdictions affected by the data privacy laws.
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Personal Data Inventory & Flow Mapping
- Identify and categorize all personal data processed by the organization.
- Map out how personal data is collected, processed, stored, and transmitted.
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Data Subject Rights Assessment
- Review processes to allow individuals to exercise their rights (access, deletion, portability).
- Ensure that personal data can be retrieved and deleted upon request.
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Consent Management Review
- Assess mechanisms for obtaining and managing consent for data collection.
- Review consent forms, checkboxes, and tracking systems for GDPR/CCPA compliance.
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Privacy Policy & Notice Review
- Review and update privacy policies to ensure clarity, transparency, and compliance with GDPR/CCPA.
- Ensure that privacy notices include all required information regarding data processing activities.
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Third-Party Vendor Risk Assessment
- Review data processing agreements (DPAs) with third-party vendors to ensure they meet GDPR/CCPA standards.
- Evaluate vendors’ data protection practices and ensure proper data transfer mechanisms are in place.
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Security Controls & Breach Response Review
- Ensure data protection controls (encryption, access controls, etc.) are in place to secure personal data.
- Review the organization’s data breach detection and response plan for GDPR/CCPA compliance.
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Gap Analysis & Remediation Recommendations
- Conduct a gap analysis of existing data protection practices against GDPR/CCPA requirements.
- Provide actionable remediation steps to achieve full compliance.
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Final Compliance Report & Roadmap
- Prepare a detailed compliance report with findings, recommendations, and a roadmap for addressing gaps.
- Provide guidance on achieving full GDPR/CCPA compliance.
11. GDPR / CCPA Readiness Checklist
1. Personal Data Inventory and Mapping
- Maintain an up-to-date inventory of all personal data processed.
- Map out data flows and processing activities across departments and third-party vendors.
- Identify the legal basis for data processing (e.g., consent, contractual necessity, legitimate interests).
2. Data Subject Rights Compliance
- Implement processes for data access requests, deletions, and portability as required by GDPR/CCPA.
- Ensure individuals can easily exercise their rights to restrict processing and object to automated decisions.
- Document all requests and responses to demonstrate compliance.
3. Consent Management
- Ensure that consent for data collection is freely given, informed, specific, and unambiguous.
- Implement processes to document and store consent records securely.
- Provide individuals with an easy mechanism to withdraw consent.
4. Privacy Policy and Notices
- Ensure that privacy policies are clear, concise, and include necessary GDPR/CCPA-required details (e.g., purposes for processing, data sharing).
- Regularly update privacy notices to reflect changes in data processing activities.
- Ensure that the policies are easily accessible by data subjects.
5. Third-Party Vendor Risk Management
- Review and update Data Processing Agreements (DPAs) with third-party vendors.
- Ensure that vendors meet GDPR/CCPA security and privacy standards.
- Implement monitoring mechanisms for third-party compliance.
6. Security and Breach Notification
- Implement strong data security measures such as encryption, pseudonymization, and access controls.
- Ensure that a robust breach detection and reporting mechanism is in place.
- Maintain a clear breach notification process and ensure that it meets the GDPR/CCPA timelines (72 hours for GDPR).
7. Documentation and Reporting
- Maintain thorough documentation of all data protection activities and decisions.
- Keep records of data subject rights requests, consent records, and data protection impact assessments.
- Regularly audit data processing practices and privacy policies to ensure ongoing compliance.