PRIV- 1 Privacy Governance Program

What is this control about?

Implementing a ‘Privacy Governance Program’ is crucial for organizations to effectively manage and protect sensitive personal data. In today’s digital age, the volume of personal information collected and processed by businesses is increasing rapidly. This information includes customer data, employee records, financial details, and more. Ensuring the privacy and security of this data is of paramount importance to maintain trust with stakeholders and comply with relevant data protection regulations.

A ‘Privacy Governance Program’ provides a structured framework for managing and safeguarding personal information throughout its lifecycle. It sets out policies, procedures, and guidelines that define how the organization collects, uses, stores, and discloses personal data. The program establishes roles and responsibilities, assigns accountability, and outlines processes for handling data breaches and privacy incidents.

Available tools in the marketplace

Tools:

No tool recommendation is made for this section

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: 

• Privacy Committee Charter Template

Control implementation

In general, you can establish a privacy committee charter to document and monitor the organization’s compliance with data protection laws, regulations, and internal privacy policies. However,  the following steps should be considered when implementing a Privacy Governance Program.

• Management Support and Commitment: First, obtain management support and commitment to establish a Privacy Governance Program. This includes appointing a designated Privacy Officer or Data Protection Officer (DPO) responsible for overseeing privacy initiatives.
• Privacy Assessment and Data Inventory: Then, conduct a thorough privacy assessment to identify the types of personal data collected, processed, and stored by the organization. Create a data inventory to document the categories of data, the purposes of processing, and data flows.
• Applicable Laws and Regulations: Identify and understand the relevant data protection laws and regulations that apply to the organization based on its geographic locations and the jurisdictions where it operates. This includes GDPR, CCPA, Health Insurance Portability and Accountability Act (HIPAA), or other sector-specific regulations.
• Privacy Policies and Procedures: Develop comprehensive privacy policies and procedures that outline the organization’s commitment to privacy protection. This includes policies for data collection, consent, data retention, data subject rights, and data breach response.
• Privacy Training and Awareness: Conduct privacy training for employees to ensure they understand their roles and responsibilities in safeguarding personal data. Regularly reinforce privacy awareness through ongoing training and communication.
• Privacy Oversight: Establish an oversight body to ensure that the privacy security goals are met. A privacy committee charter can be implemented as a formal document that outlines the purpose, responsibilities, composition, and authority of a privacy committee within the organization. The charter can serves as a foundational document, establishing the framework for the committee’s operations, and guiding its members in carrying out their roles effectively. The primary goal of a privacy committee will be to oversee and ensure the organization’s compliance with data protection laws, regulations, and internal privacy policies.
• Privacy Metrics and Reporting: Develop privacy metrics to measure the program’s effectiveness and report privacy performance to management and relevant stakeholders. Set up a  recurring meetings  to review and discuss the metrics.

What evidence do auditors look for?

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

1. Provide the Privacy committee charter document
2. A recurring calendar invite for the privacy committee meeting.
3. Privacy committee meeting minutes.

Evidence example

For the suggested action, an example is provided below:

• Provide the Privacy committee charter document

Use this Privacy Committee Charter Template

• A recurring calendar invite for the privacy committee meeting.

• Privacy committee meeting minutes.