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How to Kick-off a Privacy Management Program

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A successful privacy management program relies on the privacy governance structure that you’ve built within your organization. There's a high risk that many privacy efforts go to waste due to a lack of privacy governance and accountability structure.  

Adhering to data privacy regulations requires in-depth knowledge of business processes, industry, technology, and privacy laws and regulations. Unfortunately, many organizations don’t address their privacy management maturity or competencies regularly, potentially leading to non-compliance. Privacy laws are constantly evolving, so having a solid infrastructure will allow you to maintain compliance more efficiently.  

This article will explain what privacy governance is and why it’s essential to your organization. We’ll also go in-depth into privacy governance components to build a solid foundation for your privacy management program.   
 

Data Governance  

Let’s first talk about data governance. Data governance and privacy governance are closely related but not the same.   

Data governance is about managing the quality and integrity of all data across an organization. It ensures a consensus and truth in the data. It can be relied on to be accurate and complete for all functions across departments.  

It’s relevant to privacy governance because personal information must be secured and protected to ensure its quality and integrity to preserve data privacy.   
 

Privacy Governance  

Privacy governance refers to the components that enable compliance with privacy laws and regulations, supporting the organization’s broader business objectives and goals. These components include:  

  • Defining the privacy program scope   
  • Assigning accountability for privacy and responsibility of the privacy program  
  • Developing and maintaining an organizational privacy strategy  
     

Define the privacy program scope   
 

Every organization has unique privacy compliance obligations, depending on the nature of your business and the type of information you’re collecting. A typical approach to identifying the program scope includes the following.  

  1. Identifying the personal information collected and processed.  
  2. Identifying applicable privacy laws and regulations.  
When deciding your organization’s privacy policies, you need to consider local and international laws. How do they affect the data that your business processes? Most multinational organizations are subject to various privacy laws. 

Some key questions to consider in defining the scope of the privacy program are:  

  • Who collects, uses, and maintains personal information relating to individuals, customers, and employees? This includes your service providers, so you need to understand these roles and obligations.  
  • What types of personal information are collected, and what is the purpose of collection?  
  • Where is the data stored physically?  
  • To whom is the data transferred?  
  • When (e.g., during a transaction or hiring process) and how (e.g., through an online form) is the data collected?  
  • How long is data retained, and how is it deleted?  
  • What are security controls in place to protect the data? 

Assign accountability and responsibility for your privacy program  

Demonstrate senior management commitment and support  

Your organization’s senior management has a significant role in initiating the privacy management program. To demonstrate commitment to data privacy, they should be responsible for your company’s handling of personal data. Senior management can provide leadership in various ways, including:  

  • Defining strategic organizational values and principles to align data protection obligations and responsibilities within the organization  
  • Allocating resources (e.g., budget, workforce) to data privacy  
  • Appointing and empowering the privacy officer  
  • Monitoring and managing privacy risks  
  • Providing strategic guidance on the implementation of privacy initiatives  
  • Approving the organization’s privacy policies and privacy management program  
  • Commissioning privacy impact assessment  
  • Advocating data protection training  
  • Providing direction to the privacy policy for handling major complaints and managing data breaches, including implementation of remediation plans  
  • Providing direction to the privacy officer for communication and liaison with the data privacy authorities 

Without senior management’s support, it will be challenging for your privacy management program to kick-off, let alone progress.  

Designate an individual responsible for privacy compliance  

Some jurisdictions require organizations to appoint a privacy officer. Review the privacy laws in areas where your business operates to determine if you must have a privacy officer. Nevertheless, it’s best practice to designate at least one individual responsible for all privacy matters, whether needed or not.  

GDPR has a general EU-wide obligation to appoint data protection officers (DPO). This role is responsible for overseeing the privacy management programs within organizations. Most of the privacy laws outside Europe do not explicitly require the appointment of a DPO. Regardless, some privacy authorities have emphasized that the function of a DPO is considered an essential and strategic component for maintaining accountability.  

The privacy officer plays a central role as an advocate for both customers and employees. Without the privacy officer, you risk having an ineffective privacy program and poor alignment with relevant laws.  

Develop and maintain an organizational privacy strategy  

After identifying a privacy management program, you need to establish your privacy strategy. This process will involve various stakeholders and consider business alignment, data governance of personal information, and procedures for handling inquiries or complaints.  

A privacy strategy should lay out the goals of the privacy program. It’s your company’s approach to communicating and obtaining support for the program. Building a privacy strategy may mean changing the mindset and perspective of your entire organization. Everyone in your organization has a role in protecting the personal information a business collects, uses, and discloses.                                                          

If gaining management buy-in is difficult, it’s helpful to conduct a workshop for all stakeholders to support efforts to develop and launch a privacy program. This ensures that everyone is on the same page in terms of privacy. It’s not safe to assume that all stakeholders have the same level of understanding of the regulatory environment or complexity of the undertaking. This is an opportunity to put everyone on the same page regarding organizational risks and challenges, data privacy obligations, and increasing expectations in the marketplace toward protecting personal information.  

It’s also essential to document privacy-related activities, meetings, and agreements or decisions. When privacy is addressed in an ad hoc manner with no record or documentation, the effectiveness and consistency of your efforts decrease significantly. Also, the likelihood of privacy governance mistakes occurring increases. A well-functioning privacy governance framework is necessary to ensure that you can implement a compliance program and achieve the desired results.  

Get started with privacy governance  

Effective privacy governance combines organizational and operational aspects to promote privacy accountability. Privacy governance is about getting all departments to work together using the strengths and capabilities of each department effectively.   

If there is no privacy governance, there is a risk that stakeholders may make decisions in areas where they do not have the authority or required competencies, or worse, fail to address some issues entirely.  

Successful privacy program management requires a clearly determined program scope, thoughtful strategy, and supporting stakeholders who remain committed throughout the program’s lifecycle. Ready to get started with privacy governance? Check out our solutions.