What practical controls help an SMB manage personal data

01

The answer in brief

An SMB can manage personal data soundly by combining three elements: a record of processing activities, organizational measures such as training and internal policies, and technical measures such as authentication, encryption and backups. The record describes the purpose, categories of data, recipients and retention period of each processing activity and is the responsibility of the organization's controller.

02

Why structured control is needed

Personal data is any information that identifies a person, either directly (first name, surname) or indirectly (customer code, booking reference). A breach can cause financial loss, fines and a drop in customer trust, which is why preventive cyber-security is essential.

03

The operational path

Steps

1. Identify activities that involve personal data processing, such as hiring, payroll or badge management.
2. Fill in the record with purpose, categories of data, recipients and retention period.
3. Define a binding internal policy on data protection and security.
4. Regularly train data handlers on privacy risks and procedures.
5. Implement technical measures: authentication, encryption, backups, periodic review of authorizations.

04

Hypothetical example

Hypothetical example: a small company managing payroll records surname, first name, date of birth and salary of employees in its record of processing activities, listing the human resources department as recipient. For employees using personal devices (BYOD) to access the network, the company applies data encryption and requires authentication, maintaining the same level of security regardless of the equipment used.

05

Technical and organizational controls to check

• Provide a unique identifier and require authentication for access to systems.
• Manage authorizations with separate profiles and strong passwords, with periodic review.
• Encrypt or pseudonymize data to limit re-identification of individuals.
• Sign confidentiality agreements with employees and limit USB media.
• Conduct training and awareness sessions on security with periodic reminders.

06

How to structure this work with management software

A business can ask its software partner to set up a digital record of processing activities that tracks purpose, data categories and recipients for each process, with distinct roles for those who enter and those who verify entries. It is useful to schedule a periodic review of access authorizations and a traceable training flow for data handlers, so as to keep evidence of the organizational measures adopted.

07

Practical frequently asked questions

Who is responsible for the record of processing activities? The record falls under the responsibility of the organization's controller and must be available to the competent data protection authority upon request.

Do small organizations have to record everything? Organizations with fewer than 250 employees do not have to mention purely occasional activities in their record, such as data processed for a one-off event.

08

Next step

Start mapping your SMB's processing activities beginning with the most critical ones, such as payroll and customer management, and build the record together with the first list of technical controls to check.