Aligning Data Protection and IT Security Policies

In today’s regulatory climate, UK organisations must meet legal and practical duties to protect personal data and maintain strong cyber security. This requires clear data protection and IT security policies. In our experience, these policies are often mixed up, which is a pitfall that undermines compliance and effective governance. Data protection and IT security policies are essential, but they serve distinct purposes, are governed by different frameworks, and are typically implemented and managed by two separate, yet aligned, groups.

The Difference Between Data Protection and IT Security Policies

At a high level, data protection refers to the legal and ethical management of personal data - how it is collected, processed, stored, shared, and ultimately deleted. Data protection requirements are primarily shaped by the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and related legislation. The focus is on ensuring individuals' rights are respected, including their right to access, rectify, restrict, and erase their personal data.

In contrast, IT security policies focus on the tools, technologies, processes and procedures used to protect an organisation's digital infrastructure and information assets. These policies cover a range of topics like acceptable use, mobile device usage, firewall management, access control, encryption, incident response, and network management, to name a few. The goal of IT security is to protect the confidentiality, integrity and availability of information and systems.

• Confidentiality - keep data private and accessible only to authorised individuals

• Integrity – ensure data is accurate, consistent, and free from unauthorised alteration

• Availability - guarantee data and systems are accessible to authorised users when needed.

Blurring the lines between data protection and IT security policies can have serious implications:

Regulatory Non-Compliance with Data Protection 

Clear accountability structures and documentation for data protection are mandated in the UK GDPR. Should an organisation present IT security measures as their primary or sole response to data protection, they risk falling short of legal requirements. Data protection is not only about keeping data secure - it’s about ensuring fair, lawful, and transparent processing. Failing to address this wider context could lead to enforcement action, fines, or reputational damage.

Ineffective Governance When IT Security and Data Protection Overlap

Good governance depends on clear policy ownership. Data protection is typically overseen by a Data Protection Officer (DPO) or compliance team, while IT security is often managed by an IT team and/or cyber security experts in the team. If these responsibilities are not clearly delineated, gaps or overlaps in coverage may occur. For example, a data breach response plan may be incomplete if it doesn’t include both the technical mitigation steps (IT security) and the legal reporting obligations (data protection).

Lack of Clarity for Staff

Employees need clear guidance on what is expected of them. When data protection policies are comingled with IT security measures, staff may become confused about their responsibilities. Separation of these two types of policy ensures training and policy documents are accessible and tailored to the needs of different roles.

Incomplete Risk Management

Risk assessments in data protection consider impacts on individuals’ rights and freedoms, such as privacy risks or discriminatory effects. IT security risk assessments, meanwhile, evaluate vulnerabilities in infrastructure or system access. Conflating these can lead to important risks being overlooked. For instance, focusing solely on encryption strength may miss the legal requirement to minimise data collection or avoid unnecessary profiling.

Best Practices for Aligning Data Protection and IT Security Policies

To ensure compliance and operational efficiency, it is recommended that organisations maintain distinct but aligned sets of data protection and IT security policies. Each set should have a clear scope, appropriate ownership, and tailored procedures. However, they must also be uniform where relevant - such as in breach response planning or third-party risk management.

For example:

• A data protection policy might outline the lawful basis for processing personal data, data subject rights, and the organisation’s approach to data minimisation.

• IT securities policy would describe how data is encrypted, how systems are patched, and how access to data is controlled.

These policies should be cross-referenced where necessary but not combined. Doing so dilutes their focus and risks confusing legal obligations with technical controls.

Conclusion

Organisations must be foresightful in developing coherent, purpose-specific policies for privacy and cyber security purposes. Treating data protection and IT security as interchangeable elements can lead to compliance failures, internal confusion, and a greater exposure to risk. By separating these domains (and simultaneously maintaining their strategic alignment) organisations can demonstrate accountability, enhance trust, and better protect both their information and their people.

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Policy Management as Service (PMaaS) helps organisations lay the foundations for a secure computing environment. The service makes the development, delivery and maintenance of polices for IT security and governance very efficient. A range of administrative functions make ongoing policy content management easy and provides visibility of user engagement with the service.

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