Technical and organisational measures
according to Art. 32 Sec. 1 GDPR for Controller (Art. 30 Sec. 1 lit. g) and processor (Art. 30 Sec. 2 lit. d)
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1. Pseudonymisation
The goal of pseudonymisation is to make it impossible to associate personal identifiable information (PII) to any specific person without access to additional information. The supplementary information must be stored seperately and is subject to technical and organisational measures.
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Authorisation for de-pseudonymisation is restricted to special privileged user accounts
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Run the pseudonymisation procedure as soon as possible, especially in case of statistical data
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2. Encryption
The goal of encryption is to convert personal identifiable information into a non-readable format, using specific procedures and algorithms.
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Encrypting PII in transit, by utilising appropriate transmitting mechanisms and protocols (i.e. HTTPS, SFTP, ...)
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Encrypting at rest, when stored on storage mediums
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Integrated state of the art encryption procedure, when storing relevant data in a database
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3. Ensuring confidentiality
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Electronic access control
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Key management and designation of authorised personnel
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Visitor management, documented arrival and departure times, always accompanied by internal employees
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Motion detector and CCTV in areas with high security requirements
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Alarm system
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Intrusion detection system
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Door safeguards
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User access authentication and authorisation in all systems
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User authentication with minimal standards for passwords
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Password policy enforced by GPO
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Password management tool for all employees
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Application-based Firewall
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Intrusion Detection und Intrusion Prevention
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Antivirus with daily update and integrity check on endpoints
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Patch management with regular updates of threatened software components
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VPN secured remote access
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Two factor authentication
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Regular training for employees regarding IT-security and data protection topics
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4. Ensuring integrity
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Audit logs for online system access
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User access authentication and authorisation in all systems
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Least privilege principle (reviewed annually)
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Storage of storage media in security zone, for example fire secured security lockers
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Encryption in transit
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5. Ensuring availability
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Backup with recurring recovery training
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UPS in all server rooms
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Redundant climate control in all server rooms
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Environment monitoring in all server rooms (leakage, humidity, temperature, smoke)
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Alarm system monitoring by professional security services
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6. Ensuring systems resilience
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Full separation of production and test systems
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Policies for development, system and software testing
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Redundant hardware
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Regular load tests for hardware components
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7. Procedures for recovering availability of personal identifiable information after a physical or technical incident
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8. Procedures for permanent review, assessment and evaluation of technical and organisational measures effectiveness
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