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The Data Importer is obligated to ensure that
• It has implemented the information security controls such as policies, practices,
procedures and organizational structures to adequately protect the confidentiality,
integrity and availability of its own data and the data of its data exporter

• The lT, technology and outsourcing services which it provides to the data exporter
are adequately secure and reliable

• It processes the personal data only on behalf of the data exporter and in compliance
with its instructions and contractual clauses
• If, for any reason, it cannot provide such promised levels of compliance, it shall
promptly inform the data exporter of its inability to comply, in which case the data
exporter is entitled to suspend the transfer of data and/or even terminate the service
agreement (contract)

• It shall promptly inform about the legislation related changes to the data exporter as
soon as it becomes aware, in which case the data exporter is entitled to suspend the
transfer of data and/or even terminate the service agreement (contract)

• It can provide at least the following (contractually agreed) technical and
organizational standards and measures -

 Acceptable Use
 Access Management
 Anti-Malware
 Data Management and Data Protection
 End User Computing
 Application Security
 Licensing
 IT Performance, Risk and Compliance
 Logging and Monitoring
 Mobile Devices Security
 Cloud computing and Storage
 Patching
 Remote Access Security
 Third party Management
 Vulnerability Management and Penetration Testing
 Web Application Security Testing

to be able to provide reasonable assurance to the data exporter

• It shall securely maintain the records of its data processing activities


92 Cyber Warnings E-Magazine – April 2017 Edition
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