You are the ISSMP for a multinational retailer that operates in the European Union and the United States. The Chief Human Resources Officer asks you to approve a new employee monitoring tool that captures screenshots, keystrokes, and application usage on all corporate endpoints. Legal counsel in the EU has not yet been consulted. As the ISSMP, which action best demonstrates alignment of security leadership with legal and privacy obligations before the tool is deployed?
A DPIA is the GDPR-mandated process for high-risk processing such as systematic employee monitoring. Involving legal counsel and the works council ensures lawful basis, proportionality, and consultation requirements are met. This directly aligns security leadership with privacy and employment law obligations before any deployment decision, reducing regulatory and reputational risk.
Why this answer
Employee monitoring is high-risk processing under GDPR, so a DPIA must be completed before deployment. Involving legal counsel and the works council ensures the security program respects privacy, employment law, and consultation requirements. The ISSMP's role is to integrate legal and privacy governance into security decisions rather than treat monitoring as a purely technical control.
Exam trap
The trap here is assuming that a signed vendor contract or an acceptable use policy alone makes employee monitoring lawful, when GDPR requires a DPIA and consultation for high-risk processing.