Data Breach Assessment

Data Breach Assessment Template for Denmark

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Document background

The Data Breach Assessment is a critical document required when organizations experience a security incident involving personal data under Danish jurisdiction. It serves as a formal evaluation tool to comply with notification requirements under both the Danish Data Protection Act and GDPR, while providing a structured analysis of the incident's impact and required actions. This document becomes necessary when there is a suspected or confirmed breach of personal data security, requiring organizations to assess the nature, scope, and potential consequences of the breach. The assessment helps organizations determine their notification obligations to the Danish Data Protection Authority (Datatilsynet) and affected individuals, while documenting the incident handling process and proposed remediation measures. It includes technical details of the breach, impact analysis, risk assessment, and compliance evaluation, serving as both a regulatory compliance document and an operational guide for breach response.

Suggested Sections

1. Executive Summary: High-level overview of the breach incident, key findings, and critical recommendations

2. Incident Overview: Basic details of when and how the breach was discovered, initial response actions taken

3. Breach Classification: Assessment of breach type, severity, and categorization under relevant regulations

4. Data Impact Analysis: Details of what data was compromised, including personal data categories and number of affected individuals

5. Risk Assessment: Evaluation of risks to affected individuals and organization, including immediate and potential long-term impacts

6. Regulatory Compliance Analysis: Assessment of breach against GDPR and Danish legal requirements, including notification obligations

7. Root Cause Analysis: Technical and procedural investigation of how the breach occurred

8. Containment Measures: Actions taken or recommended to contain and mitigate the breach

9. Required Actions: Mandatory steps that must be taken for regulatory compliance and risk mitigation

10. Timeline of Events: Chronological sequence of the breach discovery, response, and assessment activities

Optional Sections

1. Third-Party Impact Assessment: Analysis of impact on third parties and their data - include when breach affects vendors, partners, or service providers

2. Cross-Border Implications: Assessment of international data protection requirements - include when breach affects data subjects in multiple jurisdictions

3. Industry-Specific Compliance: Analysis of sector-specific regulatory requirements - include for regulated industries like healthcare or financial services

4. Business Impact Analysis: Assessment of financial and operational impacts - include for breaches affecting business operations

5. Media and Communication Strategy: Recommendations for public relations and stakeholder communications - include for high-profile or public breaches

6. Insurance Coverage Analysis: Assessment of applicable cyber insurance coverage - include when insurance claims are relevant

Suggested Schedules

1. Technical Investigation Report: Detailed technical analysis of the breach, including system logs and forensic findings

2. Affected Data Inventory: Comprehensive list of compromised data types and affected data subjects

3. Evidence Collection Log: Documentation of all evidence gathered during the investigation

4. Notification Templates: Draft notifications for data subjects, authorities, and other stakeholders

5. Security Gap Analysis: Assessment of security controls and identified vulnerabilities

6. Response Activity Log: Detailed log of all response actions taken since breach discovery

7. Remediation Plan: Detailed technical and procedural recommendations for preventing similar breaches

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