- Data Privacy is an essential concern in organisations, but a nation-wide, common framework around consumer data privacy does not yet exist.
- The Data Privacy Frameworks in response to regulatory initiatives can be repurposed to build stronger client relationships, emphasizing five core capabilities.
- A control framework helps address privacy risk and identify the areas of focus and questions they should ask, as well as who should respond.
All organisations should start their data privacy journey by assessing how information enters their organization and how it sits within applications. Likewise, they should examine the complexity generated by unstructured data sources over decades of organic growth and the lack of a good data retention schedule. Firms that can understand and take ownership of their customer data challenges in innovative ways can gain a competitive advantage in a challenging marketplace.
Many organisations have and are continuing investing in holistic activities, approaches and tools to address compliance needs related to global emerging privacy regulations such as consumer rights.
Many organisations with global operations or aspirations have implemented frameworks to respond to large-scale legislative requirements, such as the European Union’s General Data Protection Regulation (GDPR), Thailand PDPA, Brazil LGPD to mention a few. These can be repurposed with a focus to proactively build stronger client relationships, and with an emphasis on five core capabilities:
Privacy program governance
Organisations from startups to PLC levels can consider establishing roles such as data protection officer or chief privacy officer, so they are authorized to highlight risks and make required changes. Remember A DPO role has to be independent or all roles that could result in a conflict of interest. Large fines have been issued to organisations where for example an IT manager, legal associate, has also been given the role of DPO
Data discovery and classification
A privacy program may need to focus closely on discovery, inventory, and classification of personal information. Key actions within frameworks should include:
- Data Mapping
- Privacy Policies
- Data Contracts
- Employee Training
Process design and implementation
Providers may want to design processes to manage all client requests related to privacy—from beginning to end—including access to information, opt out or erasure requests.
Institutions should leverage capabilities to protect personal data across all applications, workstations, servers and the data supply chain, in accordance with the overall privacy strategy.
Training and awareness
Providers can offer training at two levels—enterprise-wide training to build overall awareness, and role-based training for front line staff handling consumer inquiries, ranging from consumer contact teams to social media specialists or those managing online platforms.
Establishing a control framework
Each function has a role to play in a data privacy transformation, but all functions should be aligned in terms of business strategy and execution. As for the three lines of defense, each has a specific area of focus their senior stakeholders and teams should be paying attention to during the transformation.
- First line of defense: Business and operational management can help keep the focus on the consumer while dealing with near-term priorities such as how the business can process data access requests.
- Second line of defense: Those directly responsible for risk management can coordinate privacy policies and associated controls related to data collection and information request procedures, while providing a sustainable and suitably high-touch advisory model for the business going forward.
- Third line of defense: Audit functions should broaden their focus on privacy to properly address the expanded scope of programs and controls going forward, and to prioritize the items for management attention.
Beginning the transformation
In today’s data-rich business environment, organisations have an opportunity to seize. Through a comprehensive framework, and existing data privacy structures and processes, they can create more transparent, trust-based relationships with clients.
Why stop at mere compliance?
See how Relentless Data Privacy Services can help you build a data privacy framework that grows with your organization and operations.