ACME Tech, an international software development company, has failed a recent audit due to not keeping adequate records of its European users' data activities. As the security manager, what is the most immediate action to take to rectify this situation and prevent substantial financial repercussions from European regulatory authorities?
Initiate a comprehensive review of the company's physical and electronic access controls.
Arrange an immediate security training session for the development team to reinforce best practices in secure coding.
Correct the record-keeping deficiencies to conform to the data-protection standards set forth by European authorities.
Deploy an updated firewall and intrusion-prevention system to better protect the perimeter of the corporate network.
Under the EU GDPR, Article 30 obligates controllers and processors to maintain detailed records of processing activities involving personal data. Failure to keep these records can lead to administrative fines of up to €10 million or 2 % of global annual turnover, whichever is higher. Therefore, the highest priority after the audit finding is to remedy the record-keeping gap and bring documentation into full compliance. While reviewing access controls, improving perimeter defenses, or holding training sessions may strengthen the overall security program, they do not directly address the specific violation that triggered the audit failure and potential fines.
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