Key points:
- Businesses must comply with GDPR requirements regarding the protection of personal data.
- They must ensure data security in order to prevent the risk of data leaks, hacking or misuse.
- The implementation of data governance structures the policy for managing and processing information flows.
- This management is a major challenge for businesses in the face of digital and technological development.

In an era characterised by an explosion in data volumes, businesses are required to implement an effective privacy and data management policy. They are obliged to comply with the GDPR, which aims to regulate and secure the processing of personal data. Reveals supports you in understanding this regulatory framework, identifying the key issues and implementing practical measures tailored to your business.
What is data privacy ?
Data privacy refers to all measures designed to protect personal information collected by an organisation, whilst ensuring that individuals retain control over its use. It helps prevent any unauthorised access, use or disclosure.
Personal data refers to any information that allows a natural person to be identified, either directly or indirectly. This may include their first and last names, telephone number, email address, online credentials, national insurance number or IP address.
Protecting this information is a major concern, as misuse can have serious consequences: unsolicited marketing, discrimination or even identity theft.
In this context, individuals must be able to retain control over their information. They have the right to be informed clearly and transparently about how their data is collected, stored and processed.
For their part, organisations are obliged to put in place protocols and technical and organisational measures to ensure information security and to comply with the principles of transparency and security.
What is the regulatory framework for the personal data management policy ?
The GDPR : the key reference
The General Data Protection Regulation (GDPR), which came into force in May 2018, harmonises practices relating to the processing of personal data at European level. Its aim is to strengthen individuals’ rights, hold data controllers accountable and provide a regulatory framework for their activities. This regulation applies to all private and public organisations that collect and process personal data, including businesses.
The GDPR is based on six key principles from which other regulations derive :
- Transparency. Individuals must be informed of how their information is processed and of their rights regarding such processing (correction, access, erasure, etc.).
- Purpose. Information must be collected for legitimate purposes of the organisation (human resources management, customer follow-up, etc.).
- The principle of data minimisation. The company must only collect data that is strictly essential for its proper functioning.
- A defined retention period. Information is retained for a fixed period. The data must then be deleted, archived or anonymised.
- Security. The company must implement all necessary measures to protect the information entrusted to it.
- Individual rights. Individuals must be able to easily access, rectify and delete (“right to be forgotten”) the information provided.
Data protection regulations are constantly evolving. It is therefore essential to keep a close eye on developments and adapt practices accordingly.
What are companies’ obligations regarding data privacy and data management ?
The company director is the data controller. As such, they are responsible for putting in place the necessary measures and protocols for the processing and protection of personal data.
Ensuring transparency and respect for individuals
Anyone whose personal data is collected must be informed of how this information is used and for what purpose. They must be provided with a full set of details on this matter, including the name of the data controller, whether the provision of this information is mandatory or not, how long the data will be retained, and the rights they have in relation to this data (access, rectification, objection, portability, erasure).
This information must be provided at the time of collection where this is direct, or within one month where it is indirect (as is the case with information obtained from public sources). It must be worded clearly and concisely so that the individual can give their consent freely, in an informed, specific and unambiguous manner. Such consent may be mandatory prior to any processing.
Do you have a website? This information must appear on your privacy policy page (which is part of the mandatory legal notices). A cookie management banner may also be implemented, but it is prohibited to pre-tick any boxes.
Without prior information, you risk a criminal fine.
These transparency requirements are not merely legal obligations: they help to foster a climate of trust and enhance your company’s credibility.
Establishing data governance
Data governance refers to the set of protocols implemented within an organisation to ensure the confidentiality, security, accuracy, availability and usability of information. It encompasses standards, technical processes and organisational systems.
To comply with the principle of accountability and ensure your company’s compliance with data protection rules, two actions are essential :
- Maintain a data register. This records all data processing activities to provide a clear overview of the actions carried out. Keeping such a register is mandatory for organisations with more than 250 employees, but also applies to those below this threshold if you process sensitive data, data relating to criminal convictions, or data that poses a real risk to individuals’ rights and freedoms. This is the case, for example, for financial or healthcare companies.
- Appoint a Data Protection Officer (DPO). A Data Protection Officer is mandatory if your company processes a large volume of data or if the nature of your business involves large-scale monitoring of individuals.
Data governance is essential for structuring the internal management of your data and driving your growth.
| At Reveals, we support you in implementing a governance policy that meets regulatory and financial requirements, as well as addressing your business challenges. This enables it to become a strategic tool for accelerating your projects in complete safety. > Discover our advisory services to help you structure and implement your data governance strategy. |
Improving security and anticipating risks
The security measures to be put in place must be proportionate to the nature of the data being processed and the specific risks associated with your business.
Regulating data processing
Start by establishing a framework for data processing :
- Identify the data processing activities and the media used ;
- Map out the interconnection and data flow diagrams from collection to deletion ;
- Draw up an action plan dedicated to your company’s IT security ;
- Schedule regular checks to identify any new risks.
Develop a logging system
A logging system records all technical and business-related user activities, as well as any anomalies or security-related events. It is an essential tool for detecting incidents and responding to data breaches.
Taking action on multiple levels
To enhance security, there are several measures that can be taken, including :
- Restricting user authentication and authorisation. Assign a unique username to each individual and limit access according to their authorisation level.
- Protecting IT equipment and the network. Installing firewalls, setting up automatic session lock-out systems, regularly updating antivirus software, segmenting the network, and deleting data from a workstation before it is reallocated are examples of common measures. Your teams must also be made aware of the risks associated with the use of mobile devices (theft, connecting to unsecured public networks).
- Securing servers. This can be achieved using the TLS protocol for data encryption, as well as malware detection software.
- Perform regular data backups (including one offline). Remember to protect these backups to the same standard as your production systems.
Assess the risks
The level of risk must be assessed on a regular basis, in line with the level of risk associated with your business. In the event of an incident, your company must be able to demonstrate that it has taken appropriate measures.
Where data processing poses a significant risk to the rights and freedoms of individuals, a data protection impact assessment (DPIA) must be carried out. This involves assessing the risks, the proportionality of the actions taken and the measures envisaged to manage them.
Create management protocols
Any security incident must be handled in accordance with a formal procedure. The document must set out the criteria for classifying the incident and the people to contact in the event of a problem. Please note that in the event of a breach that is likely to infringe on individuals’ rights and freedoms, you have 72 hours to notify the CNIL.
Monitoring data flows to third parties
If you use third-party organisations to manage your data, you should check that they offer sufficient safeguards. Request the organisation’s security policy and verify their expertise and resources. You should then draw up a data processing agreement to formalise the purpose of the processing, set out the division of tasks and responsibilities, and specify the procedures for processing the information.
If you use an organisation based outside the EU, check that its country of residence is covered by an adequacy decision from the European Commission (the list is available on the CNIL website). If no decision has been issued, you should require guarantees from the organisation: adherence to a code of conduct, the signing of a contract incorporating the European Commission’s standard contractual clauses, or the implementation of binding corporate rules.
What are the issues and challenges involved in implementing this for companies ?
The risks of non-compliance
The implementation of a privacy and data processing policy is mandatory and governed by law. In the event of non-compliance, the company faces significant financial penalties, or even criminal sanctions.
Beyond the legal aspect, any data breach also has an impact on the company’s reputation. Conversely, a strict policy serves as a means of strengthening consumer confidence.
Technological development
The digitisation of tools and storage systems (the cloud, connected devices), as well as the development of artificial intelligence and big data, are heightening the challenges associated with data management.
These developments make information processing more complex and increase the risk of potential security breaches. It is therefore essential to establish a governance policy that is adapted to current challenges.
Respecting confidentiality in data management is a major challenge in the digital transformation of businesses. Within the framework of the GDPR, the aim is to ensure the useful and consistent processing of information to accelerate the growth of organisations whilst guaranteeing data protection. Whilst these obligations represent an organisational and technical constraint, they also constitute an essential lever for building trust. Reveals supports you in establishing a governance policy tailored to your business challenges. Contact us to identify the key areas for structuring your data flow processing to accelerate your growth.
Q&A
What is personal data ?
Personal data is information that directly or indirectly identifies an individual. Examples include a surname, first name, home address, IP address, telephone number or fingerprint.
What is the difference between the GDPR and the CNIL?
The GDPR is the European regulation governing the protection of personal data. The CNIL is the French authority responsible for its enforcement within France. It supports organisations in achieving compliance.
What are the stages involved in data processing ?
Data is first collected and then recorded. It can then be used, modified or even shared if necessary. It is retained for a specified period before being deleted or anonymised.