Data Protection Unit has created a four-tier approach to
ensuring a satisfactory data protection compliance procedure by the
1. Identification: Initial compliance including audit by the firm
held in conjunction and direct relationship with the client. This
provides the firm with an initial snap-shot of the situation within
the client's environment. The initial audit to be carried out by the
firm will focus mainly on data held in electronic format and
processed automatically however focus will also be given for data
stored/processed manually since this will also require compliance at
a future date.
2. Awareness Raising: The firm and the client may at any stage agree
to devising customized awareness raising sessions amongst internal
representatives of the client.
3. Ongoing Identification and Fine Tuning:
The firm provides ongoing
advice, necessary legal drafting of any policies, forms and website
content as well as notification and reporting of any new legislation
in this field which may have an impact on the client.
4. Services of a Personal Data Representative:
The firm at this
stage will act as intermediary between Data Protection
Commissionerís Office (DPC) and the Client, as well as any sectoral
regulator where applicable. The role of the firm will be that of
providing support and clarification as well as advocate on behalf of
the client with the DPC.
The firm will also indicate to the DPC the
daily realities of work carried out by client and the way in which
this must be taken into consideration by the DPC when issuing
regulations of direct interest to the client. The firm intends to
acquire accreditation from DPC once this is offered so as to ensure
a more comprehensive accredited service for the client. The firm
will also provide assistance via written submissions to the DPC on
behalf of the client with regards to special legislation and
subsidiary regulations addressed to the sector in which the client
The Overriding Policy of our DPU
While we will not hesitate to advise on any radical changes to be
effected to bring the client in conformity, our DPUís emphasis is on
making those minimal changes absolutely necessary to bring the
client in line with current legislation so as to ensure that the
clientsí core operations continue uninterruptedly.