Section 1: Organizational Context and Governance
1.1 Has your organization established and documented the context of internal and external factors that affect its information security and data protection objectives? Consider regulatory, technological, competitive, market, cultural, social, and economic factors that may impact your information security and data protection posture.
Applicable to: Both GDPR (Art. 24) and ISO 27001 (Clause 4.1)
1.2* Has your organization identified and documented all interested parties and their requirements relevant to information security and data protection? Interested parties may include customers, suppliers, regulators, shareholders, employees, and other stakeholders with requirements or expectations related to security and privacy.
Applicable to: Both GDPR (Art. 24, 28) and ISO 27001 (Clause 4.2)
1.3* Has your organization clearly defined the scope of personal data processing activities? This should include what personal data you collect, from whom, for what purposes, how it is processed, where it is stored, how long it is retained, and with whom it is shared.
Applicable to: GDPR (Art. 30)
1.4* Has your organization established and documented the scope of your Information Security Management System (ISMS)? This should define the boundaries of your ISMS including locations, functions, assets, technology, and interfaces with external entities.
Applicable to: ISO 27001 (Clause 4.3)
1.5* Does your organization have documented evidence of executive leadership commitment for both data protection and information security? This should include formal policy approval, resource allocation, defined roles and responsibilities, and active oversight by top management.
Applicable to: Both GDPR (Art. 24) and ISO 27001 (Clause 5.1)
1.6 Has your organization appointed a Data Protection Officer (DPO) or equivalent role with clearly defined responsibilities? A DPO is mandatory for public authorities, organizations whose core activities require regular and systematic monitoring of individuals on a large scale, or organizations processing special categories of data on a large scale.
Applicable to: GDPR (Art. 37-39)
1.7 Has your organization assigned information security responsibilities to specific roles with clear authority and accountability? This includes roles like Chief Information Security Officer (CISO), security managers, and others with specific security responsibilities across the organization.
Applicable to: ISO 27001 (Clause 5.3)
1.8* Does your organization have documented information security and data protection policies approved by management? Policies should be comprehensive, formally approved, communicated to all relevant parties, and regularly reviewed and updated.
Applicable to: Both GDPR (Art. 24) and ISO 27001 (Clause 5.2)