Can you share any tips or best practices for privacy impact assessments, especially for organizations that are just starting to adopt this process? How do you ensure these are more impactful than just checking a box to be compliant?
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If you are just starting you can create a questionnaire for each project / system / process. The questionnaire should include sections such as the following:
- Type of PII collected (e.g. name, ID, address...etc.)
- How transparent is the data collection and use for the subjects.
- Data quality and proportionality.
- How data minimization is achieved.
- How storage limitation is achieved.
- The consent process.
- What subject notifications are required / implemented.
- Third party involvement as processors.
- Cross border requirements (if used).
- Can subjects rights / requests be met (e.g. right to be forgotten, right to amend / correct, generating reports of the PII collected...etc.).
To ensure it is effective it has to be integrated in the corporate governance model (e.g. include the outcome in the corporate risk register for tracking and mitigation follow up, measure the compliance by agreeing with the data business owners on scores and weightages assigned to the answers in the questionnaires and reporting the results to the management forums / committees...etc.).
- Understand how data is used throughout its lifecycle
- Involve legal, IT, and business teams early on
- Classify data based on sensitivity and regulations
- Integrate PIAs into ongoing projects
- Document risks and how they are addressed
- Link privacy protection to customer trust and brand reputation
- Identify threats, assess risks, and prioritize them
- Regularly educate people on privacy
- Consider privacy implications in new projects
- Ensure partners and vendors respect privacy in data handling
A lot of it comes back to understanding customer expectations. What are your customers expecting you to do with their data? Where do they live? We've all been in situations where actions are taken just to check a box. However, it's crucial to understand the intent behind these actions. What is your actual responsibility to your customer, and what are you trying to solve? This is really important.
When I see this question, one key point is the consistent application of PIAs. In many organizations, the implementation of PIAs can be hit or miss. It is essential to ensure that PIAs are conducted consistently as part of key business processes. Often, if a business unit is performing any shadow functions, the PIA is the last thing they consider. Consistency in applying PIAs helps in identifying risks and capturing them for remediation.
Start by engaging cross-functional teams early. Foster a culture of accountability where privacy is everyone’s responsibility. Use assessments not just for compliance but as a roadmap to identify risks, enhance data protection, and build trust with stakeholders.