BIZOPS- 59 – Privacy Risk Assessment

What is this control about?

“Privacy Risk Assessment” is crucial for organizations to proactively identify and mitigate privacy risks associated with the collection, processing, and handling of personal information. Privacy risk assessment involves systematically evaluating the potential impacts and likelihood of privacy breaches or violations, identifying vulnerabilities, and implementing appropriate controls.

Available tools in the marketplace

Tools:

TrustArc

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:

• Leverage this template and edit this for Privacy Risk Register_ISO Template

Control implementation

Here are some guidelines to implement an effective records of Privacy Risk Assessment program:

• Establish the Privacy Risk Assessment Framework: Develop a framework that outlines the organization’s approach to privacy risk assessment. Define the scope of the assessment, the methodology to be used, and the criteria for evaluating and prioritizing privacy risks. Ensure the framework aligns with privacy regulations, industry standards, and organizational goals.
• Identify and Classify Personal Information: Identify and classify the types of personal information collected, processed, and stored by the organization. Categorize the data based on sensitivity, regulatory requirements, and potential impact on individuals. This step ensures a comprehensive understanding of the data landscape and forms the basis for assessing privacy risks.
• Identify Privacy Risks: Identify potential privacy risks associated with the collection, use, storage, and sharing of personal information. Consider internal and external factors that may pose risks, such as data breaches, unauthorized access, inadequate security measures, third-party relationships, or regulatory non-compliance. Involve relevant stakeholders, including privacy professionals, legal experts, and subject matter experts, in this process.
• Assess Likelihood and Impact: Evaluate the likelihood and potential impact of identified privacy risks. Consider factors such as the likelihood of occurrence, the severity of impact on individuals, the organization’s reputation, and legal or regulatory consequences. Use a standardized risk assessment methodology or a scoring system to assess risks consistently across the organization.
• Determine Risk Levels: Assign risk levels to identified privacy risks based on the assessment results. Categorize risks as high, medium, or low based on their likelihood and impact. This step helps prioritize risk mitigation efforts and allocate resources accordingly. Document the risk levels assigned to each identified privacy risk.
• Evaluate Existing Controls: Assess the effectiveness of existing controls in mitigating identified privacy risks. Identify gaps or weaknesses in the current control environment and evaluate their impact on risk levels. This evaluation may involve reviewing policies, procedures, technical safeguards, and organizational practices. Document the findings of the control evaluation.
• Develop Risk Mitigation Strategies: Develop risk mitigation strategies and action plans to address identified privacy risks. Determine appropriate controls, safeguards, or process improvements to reduce or eliminate the identified risks. Consider a combination of technical, organizational, and administrative measures to mitigate privacy risks effectively. Document the risk mitigation strategies and associated action plans.
• Implement Risk Mitigation Measures: Implement the identified risk mitigation measures according to the action plans developed. This may involve implementing technical controls, revising policies and procedures, enhancing staff training and awareness, or establishing monitoring mechanisms. Ensure that responsibilities and timelines for implementing the mitigation measures are clearly defined and assigned.
• Monitor and Review: Continuously monitor and review the effectiveness of the implemented risk mitigation measures. Regularly assess the residual risks to ensure ongoing alignment with organizational goals, changes in the regulatory landscape, and emerging privacy risks. Maintain documentation of monitoring activities and review findings.
• Update Risk Assessment: Periodically update the privacy risk assessment based on changes in the organization’s privacy landscape, data handling practices, regulations, or emerging privacy risks. Conduct regular reviews to ensure that the risk assessment remains relevant and up to date. Document the updates made to the risk assessment process.

What evidence do auditors look for?

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

• Privacy Risk Assessment Reports: Reports documenting the results of privacy risk assessments conducted by the organization. These reports should detail the identified privacy risks, their likelihood and impact assessments, risk levels assigned, and any recommended risk mitigation strategies. It demonstrates that the organization has performed systematic privacy risk assessments and has a clear understanding of its privacy risk landscape.
• Risk Treatment Plans: Documentation of risk treatment plans that outline the specific measures and controls to mitigate identified privacy risks. These plans should include action items, responsible parties, timelines, and monitoring mechanisms. It demonstrates that the organization has developed and implemented risk mitigation strategies based on the findings of privacy risk assessments.

Evidence example

For the suggested action, an example is provided below:

• Privacy Risk Assessment Reports

Leverage this template and edit this for Privacy Risk Register_ISO Template

• Risk Treatment Plans

Leverage this template and edit this for Privacy Risk Register_ISO Template