BIZOPS- 57 – PIMS Context of the Organization

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What is this control about?

PIMS Context of the Organization” refers to the Privacy Information Management System, which encompasses the policies, processes, and controls implemented to ensure compliance with privacy regulations and protect personal information. The control “PIMS Context of the Organization” focuses on understanding and documenting the organization’s context related to privacy management.

Available tools in the marketplace

Tools:

Available templates

TrustCloud has a curated list of templates internally or externally sourced to help you get started. Click on the link for a downloadable version:

Control implementation

Here are some guidelines to implement an effective records of PIMS Context of the Organization program:

  • Establish Privacy Governance Framework: Develop a privacy governance framework that outlines the organization’s approach to privacy management. This framework should include the establishment of privacy policies, procedures, and controls, as well as the assignment of privacy roles and responsibilities. Ensure the framework aligns with applicable privacy laws, regulations, and industry standards.
  • Identify Privacy Requirements: Identify and understand the privacy requirements that are relevant to the organization based on its industry, geographic location, and the types of personal information it collects and processes. Research and analyze applicable privacy laws and regulations, such as the General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA), or industry-specific regulations. Document the identified privacy requirements.
  • Perform Privacy Risk Assessment: Conduct a comprehensive privacy risk assessment to identify and evaluate potential privacy risks and vulnerabilities within the organization’s processes and systems. Assess the impact and likelihood of privacy breaches, unauthorized access, data breaches, and other privacy-related risks. This assessment should consider both internal and external factors that could impact privacy.
  • Define Privacy Objectives: Establish privacy objectives that align with the organization’s overall goals and risk tolerance. These objectives should be specific, measurable, achievable, relevant, and time-bound (SMART). They may include objectives such as ensuring lawful processing of personal information, protecting individuals’ privacy rights, and minimizing the risk of privacy breaches. Document the privacy objectives.
  • Document Privacy Context: Document the organization’s privacy context, which includes the internal and external factors that influence privacy management. Consider factors such as the organization’s industry, size, geographic locations, data processing activities, third-party relationships, and the expectations and concerns of individuals whose personal information is processed. This documentation should be regularly reviewed and updated as the organization’s context evolves.

What evidence do auditors look for?

Most auditors, at a minimum, are looking for the below-suggested action:

  • Privacy Governance Framework: Documented privacy governance framework that outlines the organization’s approach to privacy management. This framework should include privacy policies, procedures, controls, and the assignment of privacy roles and responsibilities. It demonstrates that the organization has established a structured framework for privacy management.
  • Privacy Objectives Documentation: Documentation that defines the organization’s privacy objectives and goals. This includes specific, measurable, achievable, relevant, and time-bound (SMART) objectives that align with the organization’s overall goals and risk tolerance. It demonstrates that the organization has established clear privacy objectives to guide its privacy management efforts.

Evidence example

For the suggested action, an example is provided below:

  • Privacy Governance FrameworkAPPS 14 Privacy Management
  • Privacy Objectives Documentation

The context can be documented within the ISMS or PIMS document. Leverage this template edit this for Privacy  Information Security Management System (ISMS) Policy Template

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