For a Dutch internet service provider (ISP), H2B performed an audit with regard to the various measures that Dutch and European legislation imposes on telecom providers. This ISP provides a full triple-play (internet, television and telephony) service to its subscribers and also various additional services, such as a public Wi-Fi network.

In recent years there have been several changes within the customer’s technical infrastructure, including the introduction of modern FTTH (Fiber To The Home) techniques and the expansion of the work area. In addition, there have been several changes to Dutch and European legislation, such as the suspension of the retention obligation in April 2014 and the introduction of the AVG (Algemene verordening gegevensbescherming) in May 2018. The AVG is the Dutch interpretation of the new European legislation in the Netherlands in the area of privacy, the GDPR.

H2B has extensive experience with legislation and regulations in the area of telecommunication and has therefore been asked by the client to carry out an audit. By means of this audit, the client wanted to realize a consolidation of various measures taken with the aim of gaining a better understanding of the level of compliance. H2B has focused on the following obligations of telecom providers during the audit:

• Guaranteeing the continuity of service towards end users
• Guarantee the privacy of the end users
• Optimal support for the Dutch security services with regard to the interception of digital communication
• Delivery of telecom data to the Dutch “Centraal Informatiepunt Onderzoek Telecommunicatie” (CIOT)
• Preparation for the introduction of the GDPR and AVG

During the audit, various business processes and technical provisions were tested against the current and new legal obligations. Based on this audit, a report was drawn up containing an explanation of the relevant legislation and guidelines, a detailed description of the systems and processes involved within the scope of the customer and the areas of focus within which the customer can improve its compliance.

The report provides an excellent basis for the client to show quickly and easily the Dutch government that it takes its obligations seriously and which measures and decisions have been taken to meet these obligations. In addition, H2B has, in consultation with the customer, defined a number of follow-up processes to ensure that the current high level of compliance will continue to be guaranteed in the future. This includes a thorough preparation for the introduction of the GMM and the establishment of a periodic repetition of the audit and the accompanying update of the documentation.