Christian Bernieri - DPO Profile picture
“A fucking good DPO” - Data Protection advocate. IAPP CIPP/E - la privacy “È roba che va fatta fare a chi ne sa.” Il Blog è qui: https://t.co/iVsCzmsZtr

Apr 14, 2019, 5 tweets

1/
IMHO there are two main focus points spotted in the #Italian #DPA (Garante Privacy) sanction to Italian major political party and associations published April 4th.
They are so important that every data controller must rethink #GDPR compliance:

2/
1) OBSOLESCENZE IS A FAULT!
Data controllers have to update their software. I know that "fixing what is not broken is an error"... but you have to grant protection and patched software.

3/
2) OLD STYLE MANDATORY TECHNICAL AND ORGANIZATIONAL MEASURES ARE NO MORE MANDATORY, BUT YOU HAVE TO IMPLEMENT THEM BECAUSE THEY ARE STILL OBVIOUSLY ALWAYS NEEDED.

4/
Italian law (decree 196/2003) included a minimum set of measures. They have been cancelled because the GDPR has a different approach to what is NEEDED/NECESSARY to grant data protection.

Nevertheless, consider them necessary.
THEY ARE THE BASIS: START FORM THEM AND MOVE ON.

5/
This is a well known approach to all infosec ad privacy pros, but nobody has ever pointed it out loud and clear. Until now!
Many arguments was rised against the sanction and the DPA. NONSENSE. It is like blaming your doctor because you are drunk and feeling sick.

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