After the recent and numerous changes in legislation or practice "that we have seen in recent times, which is published here is another measure of the Guarantor Privacy introducing a new performance in the management and protection of personal data processed through systems and safety assurance of the same data and systems.
Privacy The Guarantor, in fact, with a decision of November 27, 2008 (" | preserve "access log" for at least six months in archives
holders will also facilitate an easier understanding, in its organization, the existence of any system administrators: It is important to ensure, in this way, the knowledge of the existence of such figures and those who perform similar roles in all institutions and organizations, it is stated further that system administrators, regardless of whether or appointed officers responsible for processing, individuals should always be clearly identified within the DPS and their names must be communicated or made known by all stakeholders .
According to the writer, then, to avoid unpleasant penalties, each holder must ensure that this list has been made in the next annual update of the DPS and, in cases where the holder is not required to prepare, you will be required to enter the name of system administrators in an internal document to keep updated and also available in investigations by the Ombudsman.
And if the activities of system administrators are concerned, even indirectly, services or systems that allow the processing of personal information workers, public and private owners, as employers, are required to disclose the identity or system administrators within their own organizations through special report pursuant to art. 13, Leg. 196/2003 (or you can also use communication tools such as corporate intranets, service orders to internal movement ect.). They are the exception, in each case, the cases of exclusion by law of such advertisements or knowability.
If so, then service system administration outsourced the holder is obliged to keep identification of individuals responsible for such system administrators. Holders of the treatment will have also an obligation to annual review on the work of system administrators to control whether or not compliance with organizational measures, technical and safety with respect to the processing of personal data as specified by law. In terms of exclusions, this measure does not apply to persons falling within the privacy exemption from the subject of the recent simplification measures, provided for small and medium enterprises or for professionals who process personal data only for administrative purposes and accounting.
1 - First, system administrators, or those that manage access to databases, are generally responsible operations from which to derive great responsibility and high critical to the protection of personal data they have access. Let us recall that by its nature the system administrator has a capacity for action of their own and a relationship of trust that binds to the holder in carrying out their duties (so important for companies and large public organizations and private, so that appoint him sometimes as the data). But in reality, this small figure of some significance, because it should be in charge of tasks of supervision and control of the correct use of the computer system managed and used;
2 - Secondly, the activities of backup or disaster recovery ( Privacy Code also regulated in ), the organization of network flows, management of storage media, or the simple hardware maintenance involving the possibility for such persons to act on critical information, all activities that fall within the definition of "treatment of personal data, even when the administrator does not consult it in light of such information;
3 - The typical functions of the administration of a system are specifically mentioned in Annex B of the Privacy Code , where it includes an obligation for the holders to ensure the safekeeping of sensitive components of authentication credentials. We wanted, therefore, provide more control over who actually deals dell'assolvimento of the procedures required in the Annex B, or obligations that are typically assigned to the system administrator: implementation of backups, storage of credentials, management systems and authentication authorization, ect.;
4-Finally, there are certain offenses under the Criminal Code for which the play the role of system administrator is an aggravating circumstance (as an abuse of the system operator in access to system abuse information or computer - art. 615 ter - or computer fraud - art. 640 ter - or for cases of corruption of information, data and computer programs - Articles. 635bis and ter - and damage to computer systems and telematics - Articles. quinques and 635-c).
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