SCENARIO -
Please use the following to answer the next question:
Jonathan recently joined a healthcare payment processing solutions company as a senior privacy manager. One morning, Jonathan awakens to several emails informing him that an individual cloud server failed due to a flood in its server room, damaging its hardware and destroying all the data the company had stored on that drive. Jonathan was not aware that the company had this particular cloud account or that any data was being stored there because it was not included in the data mapping or data inventory provided to him by his predecessor. Jonathan's predecessor conducted a data inventory and mapping exercise 4 years ago and updated it on an annual basis.
Renee works in the sales department and tells Jonathan that she doesn't think that account had been used since the company moved to a bigger cloud vendor three years ago. She also advised him that the account was mostly used by Human Resources (HR) and Accounts Payable (AP). Jonathan speaks to both departments and learns that each had met with his predecessor multiple times and explained they saved sensitive personal data on that drive, including health and financial related personal data and "other stuff." Jonathan also learns that the data stored in that account was not backed up pursuant to company policy. Jonathan asks his IT department who had access to that particular account and learns that there were no access controls in place, making the account available to anyone in the company, despite the purported sensitivity of the data being stored there.
Jonathan is panicking as the data can't be recovered, and he can't determine exactly what data was saved on that account or to whom it belongs. Two days later, the company receives 32 data subject access requests and Accounts Payable confirms Jonathan's worry that these data subjects' personal data was likely stored on this account. He searches for the company's data subject access request policy, but later learns it doesn't exist.
Based on the scenario above, what is the most appropriate next step Jonathan should take?
Cock
1 year, 1 month agoSsourav
1 year, 2 months ago