In recent years, data privacy laws have become a hot topic across the globe. Europe has long been at the forefront of data privacy legislation with the introduction of the General Data Protection Regulation (GDPR) in 2018. The GDPR has set a new standard for data privacy and has led to many industries making significant changes in how they collect, process, store, and use consumer data. However, it’s not just Europe that is focused on data privacy; the rest of the world is catching up.
With the proliferation of connected devices and the rise of big data, companies must take responsibility for collecting and using personal data ethically and transparently. This is where data privacy impact assessments (DPIAs) come into play.
A DPIA is a risk assessment audit designed to help organizations identify, analyze, and minimize the privacy risks that come with collecting, processing, using, storing, and sharing user data. DPIAs are one of the key components required to comply with the GDPR. DPIAs should be a crucial part of keeping customers’ information private and protected. DPIAs are recommended anytime a company begins collecting or processing personal information in a new or different way (for instance, when introducing a new product or service). Conducting a DPIA first enables privacy by design – before an organization can build a new product or feature, DPIAs ensure that privacy needs are considered first, rather than bolted on afterward.
Before starting a DPIA, companies must establish transparency with their customers and provide notice about how their personal data will be used. This approach helps customers feel more comfortable sharing their data and trusting the organization. It’s also important to allocate a budget for the PIA process and factor in the return on investment of reducing the company’s risk. The process typically involves consulting fees, tools to automate the assessment process, and employee labor to conduct the assessment. Additionally, assembling the right PIA team is critical to conducting a successful assessment. The team should include an executive responsible for the budget, privacy office staff, product managers, IT managers, marketing managers, and members of the legal team who are experts in data privacy.
A DPIA should include details on whose data is being processed, what personal information will be used, the nature, scope, and context of the processing, the purpose for which personal data will be used, identification and assessment of risks to individuals, and measures to minimize and prevent risk to individuals involved.
The DPIA process involves six crucial steps:
The first step in conducting a DPIA is identifying the need for it. This is done by conducting a privacy threshold assessment, which involves analyzing each business asset and the privacy concerns surrounding them. The analysis will determine whether personal data is collected and used in a way that requires further analysis.
Once the need for a DPIA has been identified, the second step is to describe the information flows by conducting a data mapping exercise. This involves creating a data map that shows how data flows into, through, and out of the organization. The data map will identify any gaps where data is not protected, and it will answer important questions about why data is collected, where it’s stored, and who can access it.
The third step involves pinpointing potential privacy risks. This involves examining where notice and choice to an individual are not adequate, when security controls are insufficient, and when data quality is compromised. This step helps communicate the exact privacy risks that the organization could face to stakeholders and executives.
In step 4, you begin to fix the problems you discovered earlier. A remediation plan is created to address the identified risks, and changes to privacy policies, procedures, or processes may be necessary. The remediation plan should be followed and documented to demonstrate how the organization addressed known privacy risks.
Once the remediation plan has been executed, it must be recorded for future use in the DPIA plan of record. This document should detail the problem and solution in detail, except for data covered under non-disclosure agreements. The plan of record should be accessible and useful for the next time the same product or activity is up for review or if a problem arises.
Specify the people responsible for addressing the issues you uncovered, and outline your plan of correction. This document also provides an opportunity to record the lessons learned to reduce the risk of future issues.
Maintaining data privacy and security is critical in today’s digital age. Conducting a DPIA is a crucial step for businesses to identify and mitigate privacy risks for both the company and its customers. Remote work has added a new layer of complexity, but companies can overcome these challenges by implementing digital tools and prioritizing employee well-being. Furthermore, staying up-to-date with data privacy laws and completing DPIAs are necessary components of keeping customers’ information private and protected. Businesses must prioritize data privacy to avoid fines and protect their customers’ privacy.
Contact our team of privacy experts today for professional help implementing DPIA strategies in your company.