“TOMs,” for those unversed in GDPR acronyms, refers to the “technical and organizational measures” for keeping personal data secure required under the GDPR (Art. 32) as well as under the standard contractual clauses (Annex II). Compared with the EU Data Protection Directive it replaced, the GDPR takes a more granular approach to security requirements. While … Read More » about Drafting Robust TOMs
Security
Top Five Pain Points in Data Processing Agreements
Drafting a GDPR-compliant data processing agreement (DPA) should be dead simple. After all, GDPR Art. 28 provides a specific roadmap of what to include. Yet DPAs – which are required under the GDPR whenever a processor is processing personal data on behalf of a controller – can sometimes be the tail that wags the dog … Read More » about Top Five Pain Points in Data Processing Agreements