A GDPR risk analysis is a process that can lead to serious consequences, from financial penalties to loss of customer confidence. Many organisations only realise the importance of risk management and the right selection of safeguards after the incident.
Why risk analysis is crucial for GDPR compliance
Under Article 32 of the RODO, the data controller is obliged to apply security measures appropriate to the level of risk. A risk analysis assesses where risks arise, what effects they may have and whether current security measures are sufficient.
This is where real compliance with the regulations and the conscious management of the protection of personal data begins.
ODO 24 is a comprehensive and practical approach to RODO risk analysis with an emphasis on real security and non-bureaucratic responsibilities.
Identification of the resources used in the processing of personal data
Analysis of the risks and liabilities associated with the use of specific resources
A comprehensive description of the safety measures currently applied
An assessment of the likelihood of occurrence of threats and their potential effects;
Selection of appropriate technical and organisational measures, proportionate to the level of risk
The development of a risk management plan together with concrete, practical recommendations for action
In practice, this is not a lack of documentation, but rather the absence of an up-to-date risk assessment, which most often leads to infringements.
Preliminary consultation and definition of the scope
We know your organisation, its business context and the actual scope of personal data processing.
Development of methodology and process mapping
We select a risk assessment methodology to match the scale and nature of the business and map the processing processes and key resources (systems, data, people).
Identification of hazards and fitness
We analyse data flows, identify potential sources of risk and assess current technical and organizational safeguards.
Assessment of the likelihood of an outcome
We classify identified risks into the main threats, identifying their level, relevance and impact on the security of personal data.
Selection of safety measures and recommendations
We indicate specific, proportionate risk mitigation measures to improve the level of data protection, both from an organisational and technical point of view.
Risk analysis report
We prepare a complete report in line with the requirements of RODO, ready to be presented during an audit or inspection, which at the same time provides a practical tool for operational budget planning, task allocation and implementation of additional security measures, with clearly defined priorities and recommendations for action.
Discussing the results
We present the results of the risk analysis in an understandable way, discuss the effectiveness of the current safeguards, identify key areas for reinforcement, and explain the recommended actions and priorities to facilitate decision-making and further action planning.
For those who want to protect personal data but do not have extensive data protection experience, we have prepared a risk analysis calculator for a single asset. It is a simple educational tool that helps you understand how to assess risk in practice, step by step, using a specific example.
Marcin Wieczorek
From 13 to 17 March I attended the "Course for Information Security Administrators" organized by ODO 24 sp. z o.o. I am very impressed with the high substantive level of the training staff and the comprehensive program. Working as an ABI requires knowledge not only of legal provisions but also of IT matters, which ODO 24 took into account. Noteworthy is the curriculum, which gradually introduces increasingly advanced nuances of personal data protection, starting from the legal basics and ending with practical aspects of auditing and working with documents within a company. The complete set of materials, editable documents and publications I received will facilitate my daily work as an ABI. I can certainly recommend ODO 24 as a reliable partner offering training services of a high standard.
Magdalena Węglewska
For many years we have consistently placed great importance on the protection of the personal data of our customers as well as our employees. We took an active part in creating the "Code of Good Practice for the Protection of Personal Data of Customers and Potential Customers,” developed jointly by GIODO and the Polish Automotive Industry Association. Due to the complexity and variability of the rules on personal data protection, as well as Mazda’s dynamic development in Poland and the increasing volume of data we process, we decided to entrust the ABI function to a company specialized in this field. The decision to use the services of ODO 24 was primarily influenced by the experience and competence of the team of experts, the comprehensiveness of the offering and its flexibility in adapting to our organization. After a year of cooperation we can recommend ODO 24 as a professional and reliable partner.
Agnieszka Karłowicz
We have been working with ODO24 for over a year. For us it has been a year of peaceful breathing and a sense of security: at least regarding personal data protection :-) The people at ODO are professionals who explain matters that are incomprehensible to the average person in an understandable way. They understand not only their profession but, which is very important to us, business and its requirements. A practical approach, constant advisory availability, and great relationships — all of this means I can recommend this Company to anyone who wants to work and sleep peacefully.
Tomasz Siwicki
For several years we have been cooperating with ODO 24 in the field of personal data protection. A professional team that efficiently helped us to comply with the requirements of the GDPR. We make use not only of the experts’ knowledge but also of professionally prepared e‑training, thanks to which we were able to train several hundred employees in a very short time. I highly recommend ODO 24 as a professional partner delivering services at the highest level.
It is a systematic process of identifying and assessing risks related to the processing of personal data, encompassing an analysis of threats, vulnerabilities and an assessment of the likelihood and impact of a breach of the rights or freedoms of natural persons, required by the provisions of RODO, in particular Article 32.
A risk analysis should be carried out before the commencement of new personal data processing activities, in the event of significant changes in the manner or technology of processing, and also following a security incident or a personal data breach.
The risk analysis should be carried out by the data controller, with substantive support from the Data Protection Officer (DPO) and persons possessing knowledge of business processes and the technical solutions used, in particular IT teams.
The risk analysis should be updated regularly, commensurate with the nature and scale of personal data processing, and in particular in the event of significant changes to processes, systems or technologies, after a security incident and periodically to confirm that the technical and organisational measures applied remain effective and proportionate to the level of risk (we recommend at least once a year).
A risk analysis is a basic process that every data controller should undertake. It serves to identify threats related to the processing of personal data and to assess the likelihood and consequences of a breach of the rights or freedoms of natural persons. On its basis, appropriate technical and organisational measures are selected (Art. 32 RODO).
A DPIA is a more in-depth analysis, required only in cases where processing is likely to result in a high risk to the rights or freedoms of natural persons. It includes, inter alia, a detailed description of the processing operations, an assessment of their necessity and proportionality, and an analysis of the risks and measures to minimise them (Art. 35 RODO).
RODO does not impose a single, rigid method for conducting a risk analysis. The data controller has freedom in the selection of the methodology, provided that it is adequate to the nature, scope and context of the processing of personal data and allows for a reliable identification of risks and the selection of appropriate technical and organisational measures.
In practice, it is crucial that the chosen method is coherent, documented and enables the comparison of risk levels over time, regardless of whether it is based on standards, industry best practice or a custom methodology tailored to the organisation.
The most common mistakes stem from treating risk analysis as a formal obligation rather than a practical tool for managing data security. In practice, companies often:
Yes, the risk analysis may be carried out by an external company. RODO does not prohibit the use of external experts in this area. However, it should be remembered that responsibility for correctly conducting the analysis and the implementation of adequate security measures always remains with the data controller.
In practice, support from an external company allows one to draw on experience and an objective perspective, supplement internal competencies and ensure that the analysis complies with RODO requirements. It is crucial to involve the organisation's team, in particular the Data Protection Officer (DPO), process owners and IT, so that the analysis reflects actual processes and risks.
