Privacy Management Programs
Implementing a Privacy Management Program (PMP)
A Privacy Management Program (PMP) ensures that an organization documents their policies and procedures and complies with privacy laws, protects personal data, and fosters trust.Â
Implementation involves the following key steps:
1. Establish Leadership & Governance
- Secure executive support to ensure adequate resources and commitment. Programs with executive support, can move with velocity and be more easily accepted at all levels.
- Assign a Privacy Officer or Data Protection Officer (DPO). In-depth knowledge of the appropriate laws and how to operationalize policies and procedures is mandatory. Subject Matter Experts bring those skills to the initiative.
- Define privacy policies, roles, and responsibilities (terms of reference) within the organization.
2. Conduct a Privacy Review
- Identify what personal identifiable information (PII) the organization collects, processes, stores, shares and deletes. Identify sensitive data so it can be assessed and secured accordingly.
- Map data flows to understand how information moves through the organization. Most organizations have yet to centralize their data with a single person in charge. That changes when a PMP is implemented.
- Evaluate risks, requirements, and vulnerabilities in data handling processes.
- Read more about the details of a Privacy Review.
3. Develop Privacy Policies & Procedures
- Create privacy policies aligned with legal and industry standards (e.g., GDPR, CCPA). Our current Privacy and Security Policies and Procedures Manual has 125 policies and procedures in 17 Sections.
- Establish data collection, retention, and disposal guidelines. As each Section is written, reviewed and approved, we ensure the proper logs and reporting forms are created to help operationalize the new policies and procedures.
- Define procedures for handling data subject requests (e.g., access, correction, deletion).
4. Implement Security & Access Controls
- Apply technical and organizational safeguards to protect personal data. Security and Privacy always arise together. The management and handling of sensitive data requires higher levels of scrutiny and security.
- Working with IT experts, define, document and, implement access controls, encryption, and regular security audits. Every organization is different. A good PMP adapts itself to the organization’s culture while ensuring compliance with the appropriate laws.
- Develop a confidentiality incident response plan for data breaches and privacy issues. This plan should be a key part of the staff training so everyone understands their responsibilities and what to do if they detect a breach.
5. Train Employees & Build Awareness
- Provide regular privacy training for staff. A Privacy Management Program is a continuous improvement project. All of these changes must be communicated to the staff so they, at all times, understand their role in privacy and security of personal information.
- Promote a culture of respect for the individual and their data protection through clear, repetitive, and consistent internal communications.
6. Monitor, Audit & Improve
- Conduct regular privacy impact assessments (PIAs) for new initiatives. For example, when a new software platform is being introduced throughout the organization, be sure to conduct a thorough assessment of the personal information involved.
- Establish a compliance monitoring and auditing system.
- Continuously update policies based on regulatory changes and audit findings. Then incorporate that content into the staff training sessions when applicable.
By embedding privacy into everyday operations, organizations can reduce risks, enhance trust, and maintain compliance with privacy regulations.
