- Technology

The Operationalisation of Data Privacy Principles

The passing of the General Data Protection Regulation (GDPR) has made data privacy a key subject in global business conversations. Initially, many organisations focused on understanding what was asked of them under GDPR and other similar regulations.

This development also made PDPA trainings increasingly important. PDPA training is especially beneficial for working professionals looking to update their skills so they can effectively keep up with the latest data protection trends.

Apart from PDPA training, there are also other means available to protect personal data that’s in the organisation’s care. Nowadays, organisations need to work on the operationalisation of data privacy principles if they want to maintain and achieve data privacy readiness at the operational level.

No Consistency

In most organisations, each line of business (LOB) approaches data privacy and protection differently in terms of its own siloed data sets. Granting that some LOBs are unique and will merit a specific approach, the approach still needs to align with the objectives of the DPO while tailored to the business at the same time.

Challenges Maintaining Readiness

Another challenge many organisations face is in the maintenance of a state of data privacy readiness even if there is a clear understanding when it comes to the full lifecycle of personal data. In addition, internal and external business triggers can also greatly affect the data privacy ecosystem.

Moreover, the COVID-19 pandemic has required many employees to work from home. The new use of technology has affected the current accuracy of the data flows and system inventories. Also, since the regulatory landscape is continually evolving, your readiness one day may not hold true later on.

Moving Forward

Businesses with a conventional and more siloed architecture are not required to implement significant organisational changes in order to operationalise their data privacy programs. Below are some of the ways to operationalise data privacy principles:

Build an alliance between the DPO, business, technology, and data management teams.

In many organisations, data privacy readiness has highlighted the long-standing issues regarding information governance that focus on individual LOBs and enterprise architecture. Keep in mind that “personal data” is just a subset of data.

Organisations that have integrated master data management have done some of the legwork required to operationalise their privacy programs. Some organisations have also assigned “privacy champions” or “privacy ambassadors” to improve communication and ensure everything is in alignment with the objectives of the DPO.

Ongoing training has also been proven to help. This is especially true with solutions like gamification where employees are kept engaged while enhancing information retention.

Where Appropriate, Leverage Data Privacy Management Software

While no tool can single handedly cover the whole spectrum of privacy readiness, some data privacy solutions are considered effective in certain areas like providing basic data inventories and data maps that serve as starting points. Even so, most tools cannot substitute personal interviews with business users.

Interviews also capture the objective of data—what data is being used and why. Interviews can also uncover any manual processes and data assets that may be missed by tools including paper forms and other non-electronic information assets. Tools can also be helpful in controlling access to digital personal data.

Establish Governance

As soon as the data privacy program has been operationalised, the governance committee will be responsible for making sure data privacy readiness is sustained. Ideally, the committee should have at least one representative from various areas that handle personal information.

Other ongoing responsibilities can include:

  • Evaluating survey results to monitor compliance and assess if further investigation is needed.
  • Monitoring third-party service providers and data processors.
  • Ensuring that data privacy reviews are carried out as part of due diligence.
  • Monitoring external triggers that can impact the organisation’s privacy readiness. This includes judicial clarifications of existing laws, technology innovation, and new regulations.

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