Establishing a Baseline Privacy Program
Establishing a data privacy program is crucial, but there’s no need to feel overwhelmed by the challenges it may present. If you start with realistic expectations, you can establish a framework for success.
Building your data privacy program is more of a marathon than a sprint. Instead of aiming for perfection right from the start, focus on setting up a solid foundation that meets the current legal requirements. This approach helps you avoid immediate penalties while giving you time to learn and improve. Once you’ve covered the basics, you can start fine-tuning your program, expanding your efforts, and training employees as needed. Continuous improvement is key, so as privacy laws evolve, your program can grow and adapt to meet new standards.
The Journey to Data Privacy Compliance
Data privacy and compliance demand a lot of time, money, and manpower. This makes aiming to get each component of a program perfect a non-viable task. Instead, businesses trying to prioritize privacy should focus on simply establishing a baseline privacy program—making sure they’re in compliance, but not worrying about the details just yet. This gives the organization time to learn what works. More importantly, it brings the business into legal compliance to avoid immediate penalties.
Once these minimum standards are in place, it’s time to fine-tune and scale up as necessary. For example, a long-term privacy plan requires extensive training for your employees. But not all of them need this training right away. Those who don’t directly work with data can wait a little longer while the critical employees get the training they need. Whatever your approach, continuous improvement is vital.
Steps to Create a Baseline Privacy Program
Baseline privacy standards will look different from company to company, but the steps required to create these standards are fairly universal. Let’s take a quick look at what the process includes.
Evaluate In-House Capabilities
What can your in-house team do for your privacy program? You may need to set up an internal team and a leader to spearhead the program. Carefully evaluate your required technical, budgetary, legal, and operational investments to determine what might need to be outsourced.
Conduct a Privacy Impact Assessment
Privacy impact assessments will identify every potential point of contact with customer data. Any policy or procedure that deals with collecting, storing, processing, distributing, or deleting customer information needs to be examined so you can address any problems immediately.
Conduct Risk Assessments
Identify and assess risks from a variety of perspectives via various data privacy assessments. For example, an assessment of the geographies of customers and operations will help determine which privacy regulations need to be adhered to. A risk assessment will also help classify risks from high threat levels to the lowest, so your newly formed privacy team knows what to prioritize.
Regulation Planning
Conducting business in multiple regions means having to comply with multiple data privacy regulations. Once these regulations have been identified, start looking at them with a unified lens, finding commonalities, and singling out the most stringent aspects.
In practice, this might mean comparing the GDPR and CCPA and noting that both emphasize data minimization. Adopting the most stringent aspects of data minimization rules from each law can mean that your program meets the compliance requirements for both while saving time and resources.
Documentation
Document every single step. It will demonstrate compliance during audits and identify any gaps and areas that require improvement.
Ask for Help
Establishing baseline privacy standards is an ongoing process that needs to be given the space to grow into a full-fledged, sustainable data privacy and compliance program. Engage with your legal team when required and ask for technical assistance from experts to ensure your new privacy program is starting on the right foot.
Our signature solution, 4Comply, can help you go beyond the minimum by making adding or updating privacy laws easy while maximizing your marketing potential. Contact us today to get started.