Hi !
This week, we held one of several planned webinars where we at SkoleSec and the DPIA project provide one-on-one guidance to municipalities via webinar. This time, it was Asker Municipality, and the theme was: "How to go from a system overview to a record of processing."
The video recording from the webinar will be published next week, but we wanted to share one of the points we discussed with Asker Municipality in this newsletter: namely, if you need to make changes in how you've worked with data protection, it does NOT mean that what you did before was wrong. It means that you and your organization are now more mature and have different needs that make it useful to change how you work.
This attitude that needing to adjust or make changes means that what you originally did was wrong is one we sometimes encounter. We believe it's a common mindset among those of us who work with data protection and information security.
It's somewhat in the nature of these fields that we should do things correctly. Therefore, it's not surprising that changes are often seen as a confirmation that "something was wrong."
The point of this newsletter is to remind you that this isn't true. The need to make changes is actually a neutral thing. Circumstances have changed, maybe you are indeed more mature now, and now you have different needs.
This was particularly evident with Asker Municipality. The municipality is where we believe many others are; they created a system overview in the past. This overview contains information that formally corresponds to what a record of processing should contain, but the information is tied to systems.
Now, having worked on data protection and information security for a while, the municipality needs a more comprehensive overview of how personal data are processed, beyond what is processed in each individual system.
This doesn't mean that creating a system overview was wrong. On the contrary, having a system overview was absolutely necessary to get to where Asker Municipality is today, where they feel the need to do things in new ways.
So, when you feel a bit uneasy about the work you did before, remember that you couldn't have reached this point where you now "know better" without having laid that first cornerstone!
I wish you a wonderful, privacy-friendly week-end!
Best regards,
Ida Thorsrud
Project manager national DPIA
This newsletter was translated from Norwegian to English with assistance from ChatGPT by OpenAI. While it guided our translation, we made independent editorial choices. Any discrepancies result from this combined approach.