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Managing Data Protection With Freelancers and Contractors Print

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People outside your organisation.

WHAT THEY FREQUENTLY ACCESS

Customer databases Systems with personal data Files and exports Production environments

WHAT ROLE THEY USUALLY HOLD

Processor, when handling data on your instructions.

WHAT THAT REQUIRES

A written agreement covering the usual processor obligations.

WHY IT IS FREQUENTLY MISSING

Informal engagements skip contracts entirely.

WHAT TO PUT IN WRITING

What they may access What they may do with it Confidentiality Security expectations What happens at the end Ownership of anything produced

WHAT TO PROVIDE

Individual accounts, never shared credentials.

WHY

Attribution, and revocation on departure.

WHAT TO RESTRICT

Access to production data, wherever possible.

WHAT TO PREFER

Anonymised data for development.

WHAT TO DO ABOUT EXPORTS THEY HOLD

Require deletion, and confirm it.

WHY CONFIRM

Copies on personal machines persist indefinitely otherwise.

WHAT TO DO WHEN THE ENGAGEMENT ENDS

Remove every access, across every system Rotate anything they knew Confirm deletion of local copies

WHAT TO CHECK

That removal actually happened everywhere.

WHAT TO MAINTAIN

A record of who has been granted access, and when it was removed.

WHAT TO REVIEW

Active accounts, against current engagements.


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