Six Steps to Developing a Robust Privacy Program (2024)

Hi!👋 Welcome to Advanced Access. This week, six steps you can take to develop a robust data privacy program. We're taking a look at the practices your organization should implement in its privacy programs today.

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Information professionals are faced with the challenge of complying with data privacy laws and regulations that vary across regions and jurisdictions. At the same time, the rapid growth of data and digital transformation has increased the complexity and risks of managing personal information. To protect consumers and avoid penalties, organizations need to implement effective and sustainable privacy programs.

However, many organizations lack the practical guidance and best practices for developing and maintaining a privacy program. To address this gap, let's review the factors driving change and actionable steps you can take to assure data privacy.

Drivers of Transformation in Data Security

Data security and compliance are ever-present issues for C-suite leaders across all industries. It seems like every week there is yet another high-profile data security breach to which the world’s most tech-savvy companies are falling victim. The frequency and severity of data breaches have escalated in recent years, exposing the personal information of millions of consumers and causing reputational and financial damage to organizations.

Meanwhile, data protection regulations around the world are becoming increasingly strict and diverse. From the General Data Protection Regulation (GDPR) in Europe to the California Consumer Privacy Act (CCPA) in the U.S., laws are being enacted across the globe to give consumers more control and transparency over their personal data. There are also many guidelines that do not have the force of law but are part of self-regulatory frameworks that are considered industry best practices.

With the growing demand for data security and privacy, organizations are investing more resources and efforts to enhance their data governance capabilities. According to our 2023 State of the RIM Industry survey,

Steps to Developing a Privacy Program

How can organizations improve their data privacy efforts? Here are six essential steps to consider.

1. Develop a Project Roadmap

A written project roadmap is critical to providing a manageable overview of your data privacy program. This is where you define the scope, objectives, milestones, and dependencies of your project. When building this roadmap, here are some important questions to ask:

• What specific information and data types require privacy policies?
• What personal information do we need to collect and use?
• What is the appropriate life cycle for personal information and sensitive data?
• What timelines and milestones must we meet for our privacy program to be successful?
• How and when will we reassess our privacy program on an ongoing basis?

2. Establish Roles and Responsibilities

Clearly defined roles and responsibilities are the backbone of a successful data privacy program. Your plan must hold people accountable and this requires the definition and deployment of roles that are appropriate for the culture of your organization.

A few common roles include:

• Chief Privacy Officer – A senior-level executive responsible for managing risks related to information privacy laws and regulations.
• Data Protection Officer – An independent senior or technical-level resource who ensures that the organization applies the laws protecting the personal data of individuals.
• Privacy Officer – Part of a cross-functional team responsible for building a culture of privacy, raising awareness, and ensuring compliance across the enterprise.
• Data Owner – Individuals across the organization accountable for the data within a specific domain or process.
• Data Steward – Subject matter experts and process owners with accountability for ensuring data quality, security, and privacy.

3. Conduct Data Discovery and Classification

Data discovery and classification are essential processes for identifying, locating, labeling, and categorizing your personal data assets. These processes help you understand what data you have, where it is stored, how it is used, who has access to it, and what risks it poses.

Data discovery involves scanning your data sources to find personal data elements, such as names, email addresses, phone numbers, etc. Data classification involves assigning labels or tags to your data elements based on their sensitivity level (such as public, confidential, restricted, etc.) and their regulatory requirements (such as GDPR, CCPA, HIPAA, etc.).

These practices can enhance data visibility and transparency, simplify data governance and compliance, reduce data storage costs, and improve overall data quality.

4. Implement Data Protection Measures

Data protection measures are the actions you take to safeguard your personal data from unauthorized access, use, disclosure, modification, or destruction. These measures can include technical, organizational, or legal controls that aim to prevent or mitigate data breaches and comply with data protection laws.

Some examples of data protection measures are:

• Encryption – A process of transforming plain text data into unreadable ciphertext using a secret key.
• Masking – A process of hiding or replacing sensitive data elements with fictitious or anonymized values.
• Deletion – A process of permanently removing personal data from your data sources when it is no longer needed or requested by the data subject.
• Consent – A process of obtaining and managing the permission of data subjects to collect, use, and share their personal data.
• Access control – A process of granting or denying access to personal data based on predefined rules and policies.

Data protection measures provide several benefits for your privacy program including minimizing data exposure, enhancing data security, demonstrating data protection compliance, and building trust with customers and stakeholders.

5. Monitor and Audit Data Privacy Performance

Monitoring and auditing are ongoing processes for measuring, evaluating, and improving your data privacy performance. These processes help you track the effectiveness of your data protection measures, identify gaps and issues, and implement corrective actions.

It's best practice to monitor your data privacy metrics and indicators to assess your compliance status and progress. Audit your processes by conducting independent and systematic reviews of your data privacy policies, procedures, and practices to verify their alignment with your objectives and standards.

Monitoring and auditing can help ensure your organization maintains data privacy responsibility, validate your organization's data privacy maturity, and continue to optimize data privacy practices.

6. Develop a Training Plan

Data privacy is not any one person’s responsibility. Everyone should be trained on the organization's systems and processes to ensure compliance.

Most privacy statutes require it.

Some ways of accomplishing this include workshops, online training, and/or interactive exercises to make sure everyone is up to date with policies and procedures. Users should, for instance, know which types of data they are not allowed to modify or share with third parties, recognize fraudulent attempts to obtain personal information and understand the consequences of carelessness when it comes to data privacy.

Conclusion

Data privacy is not a one-time project but a continuous journey that requires constant attention and adaptation. By following these steps, you can develop a robust and resilient privacy program that can protect your personal data assets, comply with data protection laws, and deliver value to your organization.

For more information on privacy compliance, including privacy by design and establishing retention periods, check out our whitepaper: Data Privacy for the Information Professional.