Answered Essay: Case 1: Kraft Foods Inc.: Protecting Employee Data Synopsis Kraft Foods Inc. is the largest food and beverage company

Case 1: Kraft Foods Inc.: Protecting Employee Data
Synopsis

Kraft Foods Inc. is the largest food and beverage company in North America and the second largest food and beverage company in the world. It employs a workforce of about 98,000 individuals; approximately 45,000 in the United States, and 53,000 in sixty-five countries around the world, including fourteen European Union (EU) states (Austria, Belgium, Denmark, Finland, France, Germany, Greece, Ireland, Italy, The Netherlands, Portugal, Spain, Sweden, and the United Kingdom).

When the EU Directive on the Protection of Personal Data became effective in 1998, Kraft needed to revise the means by which it collected, processed, transmitted, and stored employee data. Improvements were made to the Unified Personnel and Payroll System (UPPS) to better protect North American human resources (HR) transactions. International HR systems were converted to the SAP HR system. A Data Transfer Agreement was legally established between Kraft and its operating entities in the EU member states, which specified restrictions on personal data and mandatory data protection principles. The position of Chief Information Security Officer was created, and stronger data security policies and practices were developed and implemented throughout the company.

1.a) The EU Directive requires “appropriate technical and organizational controls” to be in place to protect the confidentiality and integrity of personal data. How can an organization determine whether its security controls are appropriate?
b) What user access controls are in place for the UPPS and SAP HR systems?

Expert Answer

a) The EU Directive requires “appropriate technical and organizational controls” to be in place to protect the confidentiality and integrity of personal data.  How can an organization determine whether its security controls are appropriate?

Successful implementation of data security depends on several factors like

  1. Security Policies, security procedures and controls depending the business objective
  2. A Security approach which is consistent with the organisational culture and values
  3. Management support for the data security and compliance
  4. A deep understanding of security requirements based on risk management.

The following questions should be addressed during control selection and implementation:

  1. What are necessary controls required to protect the information?
  2. Are the selected security controls have been implemented or is there a proper plan for the implementation?

Types of Security Checks and Controls needed –

  1. Physical Controls –
    1. Security and data equipment measures to control the physical access
  2. Technical Controls –
    1. Technology and data security measures to control access to sensitive information.

b) What user access controls are in place for the UPPS and SAP HR systems?

User access control in UPPS and SAP HR Systems-

  • Management and assignment of mitigating controls.
  • Real-time access risk analysis reporting and dashboards.
  • It can automatically find and remediate access risk violations across SAP and non-SAP systems
  • It empowers users with self-service, workflow related data access requests and data approvals
  • I can embed legal & compliance checks and risk mitigation into business processes
  • Automate reviews of user access, role authorizations, risk violations, and control assignments
  • The process is centralised and closed loop
  • You can create a comprehensive audit trail of users and role-based access control activities
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