Developing A Privacy Program
A productive and successful privacy program is the need of the hour these days because of the growing expansion of internet technology. This technological advancement has caused compliance with global privacy regulations much more challenging. The purpose of these privacy regulations is to oversee the use, collection, and treatment of someone’s personal information. In 2018, the European Union Directive on Data Protection of 1995 Act was replaced by the EU’s General Data Protection Regulation. Now various companies are required to develop a data privacy governance program. So, companies either big or small should know the importance of having an evergreen privacy compliance program. They should also hire some skilled professionals to deal with all the data governance activities.
Significance Of Having A Privacy Program
If you are planning to build up a privacy program for your company then you must know what are your goals and requirements. You must also be aware of what type of structure you will follow for the program. Those who are working on this structure and its enactment must also be aware of these things:
1. The Driving Force Behind Creating A Privacy Program
If you are formulating a formal privacy program then you must have five key issues that are the motivation of your program creation:
- Businesses must develop it due to the increased collection, use, and storage of data.
- It is also required as technology has allowed businesses to reach international clients.
- Countries have decided to regulate the raised data collection and storage.
- To manage the access of vendors to corporate data as the growth of suppliers, contractors and consultants have increased.
- The growing risk of data breaches is due to increased data collection.
2. Operational Demands To Develop The Program
Privacy considerations in a company differ according to the nature of the company’s industry and business, data and type of tasks it performs. It also depends upon the geographical setting of a business, whether it is expanded to various countries or just confined to a single place. A company should also be familiar with basic information including:
- The personal information of the employees or consumers contains even sensitive data like social security or health evidence.
- How it collects the information, the whole objective of collecting it, and who has access to it.
- How is the firm store and discards the data and the risks that are involved in the process?
- Geographical issues like the location of all the physical facilities, employees, and other assets and whether it uses cloud storage for data.
- Cross-border marketing issues like whether the company directly deals with the clients of other countries and the language used on its website.
- Company’s marketing activities and their connection with the overall sharing and storage of data. It also looks at how the third parties deal with the whole marketing process.
How To Build An Effective Privacy Office?
A company can structure its privacy office in such a way that it develops the best privacy compliance program. The key factors to building a proper structure for a company include its culture, corporate structure and size, geographic site, data threats, internal and external resources, and operational necessities. Apart from that, a company must consider privacy a crucial element of corporate risk management. The privacy team should also have the liberty to implement policies as they want. Though, in some companies, it is the CEO who directs the privacy function. Let’s have a look at the two most famous models for structuring a privacy office:
1. The CPO Model
The CPO (Chief Privacy Officer) model is a traditional strategy to structure a private office. This model works well because only one person has the authority to form decisions and accountability for the program’s outcome. However, if the company is huge the CPO model may also include country leads, divisional leads, and an executive steering company.
2. The Working Group Model
A working group model involves a privacy committee council that either formulates all the compliance decisions or simply coordinates on privacy issues and ultimate decisions are handled by other business units.
Though the working group model works well for some companies overall the CPO model is much more successful. That is because in the working group model members lack direct responsibility for privacy matters.
Task You Should Assign To Your Privacy Team
Every company requires a focused and well-directed agenda about how it can manage and govern data usage. This will help to define privacy activities for the whole privacy compliance team.
Understanding Of the Data
The privacy team must have a complete understanding of the data that a business collects. For instance, the type of data, whether it is protected electronically or on paper, its location, the countries to or between which it is being transferred, security measures, and the person responsible for its safety.
A company’s privacy team should be well aware of all the risks and vulnerabilities of the system to a data breach incident. They should develop a risk assessment process, which will then shape the requisite foundation for the company’s privacy program. This system analyses the possibility of any given threat that may occur and what harm it may cause to the company if that happens.
Examine Legal Requirements
A company should develop its privacy framework by keeping in mind its particular legal compliance capacities. These applicable laws of a particular corporation depend upon:
- The kind of data it receives
- Its jurisdictions in which the company operates, stores data, or where the person whose information is collected is located.
Formulate A Compliance Roadmap
Once the privacy team is done with the legal analysis according to the company’s recent practices, they should build up a strong compliance roadmap. This will keep all the privacy compliance efforts made by the company on track. It will also provide directions to the privacy team and important stakeholders on track regarding their future activities.
The privacy team is responsible to establish and look after the policies and internal controls. These policies ensure that the company is going on the right track and is following these rules and regulations.
How To Manage Vendors
A key factor for privacy compliance is that the team should know how to manage good relationships with vendors and third parties who also have access to the data.
Factors To Consider Before Developing A Privacy Compliance Program
If a company wants its privacy compliance program to be successful then it should keep in mind the following key factors:
- Frequent privacy training programs
- Regulating and auditing efforts made by the privacy team.
- The program will require updates after monitoring and audits. The team can then make suitable changes to the law, business, and industry standards if they need.
If you want to learn everything about setting up a privacy program for your company then you should consider taking the CIPM certification of the IAPP. It will make it easier for you to understand all the developments that you need to make in your company to develop a long-lasting and effective privacy program.