Global Privacy Enforcement Network’s annual intelligence gathering operation

International review of how well organisations have implemented Privacy Accountability into their own internal privacy policies.

This year, the Global Privacy Enforcement Network’s (“GPEN”) annual intelligence gathering operation, called a “Sweep”, looked at how well organisations have implemented the core concepts of accountability into their own internal privacy policies and programmes. Locally, the Gibraltar Regulatory Authority (“GRA”) focussed on privacy accountability in the telecommunications sector.

In short, the study looked at how organisations have taken responsibility for complying with data protection laws.

Globally, whilst there were examples of good practice, the Sweep found that a number of organisations had no processes in place to deal with the complaints and queries raised by data subjects, and were not equipped to handle data security incidents appropriately.

Kelly Ann Martinez, Team Leader in the Information Rights Division of the GRA, said:

“We are proud to have participated in the GPEN Sweep for the fifth year in a row. GPEN is an increasingly important platform for international co-operation between Data Protection Authorities globally. This year the Sweep focussed on key elements of responsible data governance, and results have demonstrated both examples of good practice and highlighted areas where there is room for improvement. This research is useful for Data Protection Authorities as it may guide future education and outreach.”

Participating GPEN members made contact with 356 organisations in 18 countries during the Sweep and came to the following conclusions:

  • Nearly three quarters of organisations across all sectors and jurisdictions had appointed an individual or team who would assume responsibility for ensuring that their organisation complied with relevant data protection rules and regulations.
  • Organisations were generally found to be quite good at giving data protection training to staff, but often failed to provide refresher training to existing staff.
  • When it comes to monitoring internal performance in relation to data protection standards, many organisations were found to fall short, with around a quarter who responded having no programmes in place to conduct self-assessments and/or internal audits.
  • The organisations that indicated that they have monitoring programmes in place generally gave examples of good practice, noting that they conduct annual audits or reviews and/or regular self-assessments.
  • Over half of the organisations surveyed indicated that they have documented incident response procedures, and that they maintain up to date records of all data security incidents and breaches. However, a number of organisations indicated that they have no processes in place to respond appropriately in the event of a data security incident.

As always, the GRA is available to anyone wishing to discuss matters which affect their privacy, or feel that their data protection rights are not being correctly addressed.

For further information please contact the GRA by telephone on +350 200 74636 or by email on