Strategies for Robust Privacy Programs

While data mapping is a critical part of a successful privacy program, it can also be a difficult, time-consuming process. Successful data mapping requires a comprehensive understanding of the data your business collects, how you process that data, and where it lives in your organization. It’s also required to be compliant with the CCPA and various other privacy laws.

An effective data map tracks the data you collect, where it’s stored, with whom it’s shared, how long it’s kept, and what it’s used for.

Many businesses struggle to make their data map a living, dynamic tool that actively updates as their company grows. Organizational data maps often start off as manually updated spreadsheets, which quickly becomes tedious and inefficient. Modern, fast-growing businesses are finding that working with a data privacy company to automate data mapping is a more efficient, less risky, and regulation-friendly way to manage the ongoing process.

Regardless of your data mapping process, it should provide your company with a better understanding of its data ecosystem, and the steps required to comply with the CCPA and other privacy regulations.

Product Spotlight:

Live Data Map

Build your privacy program’s foundation with Live Data Map. Minimize risk, reduce errors, and save time with a continuously updated data map powered by responsible automation.

• Maintain Data Integrity: Our software detects, organizes, and categorizes personal data across your business as systems.
• Automate Operations: Auto-detect which systems hold personal data instead of relying on manual, unsafe processes.
• Create a Blueprint: Understand where personal data lives across business systems at a glance.

The amended CCPA now requires businesses to conduct regular risk assessments with the goal of understanding the requirements, trade-offs, and potential harms of processing personal data. Conducting Privacy Impact Assessments (PIAs), also known as risk assessments, will help you increase awareness and be more intentional about the personal data you collect, store, share, sell, and transfer. During a PIA, you analyze, identify, and minimize privacy risks for products, projects, or activities involving personal data.

Questions to Ask During a PIA

• What types of personal data are we handling?
• Is this data inherently sensitive or otherwise specially protected?
• Why is personal data or sensitive personal data needed?
• How is this data obtained?
• Would the data be transferred or shared outside the organization?
• Could the privacy rights and reasonable expectations of individuals be met?
• Is any of this lawful, fair, transparent, and proportional?
• What issues, gaps, or levels of risk do we have?
• If not remedied, could these issues lead to privacy harm for individuals?

A PIA could reveal that you’re retaining sensitive data for longer than you need it without appropriate security measures, or notify you that a potential SaaS vendor carries a high privacy risk. Knowing these things can help you create the right data handling processes or choose a technology partner you can truly trust with your data.

Vendor & Contract Management

PIAs can also help you keep an eye on your vendors and hold them accountable.

Businesses operating under the CCPA should consider the companies they work with as extensions of themselves. If your vendors also handle consumer personal data, you should have signed contracts explicitly stating personal information will be used only as instructed, and that they must not share or sell it without written permission.

If your vendors hire other companies to handle personal information, you must ensure they’re discussing CCPA compliance with those companies.

The best thing you can do is review your contracts to verify they meet CCPA requirements.

Product Spotlight:

Risk Monitor

With Risk Monitor, you can:

• Quickly Create Privacy Assessments: Intelligent workflows auto-populate assessments and streamline collaboration.
• Manage Assessments Centrally: Create, edit, approve, and export PIAs from a single dashboard.
• Automate Assessments: Rely on 2,000+ purpose-built integrations to reliably auto-fill PIA templates.

As consumer privacy awareness grows and people seek more control over their data, it’s increasingly unsustainable to rely on manual privacy rights fulfillment processes.

Existing legislation is changing, new regulations are emerging, and companies must prepare themselves. Processing even a handful of Data Subject Requests (DSRs) each month can disrupt regular business operations and drain organizational resources.

As your business grows, expands to new territories, and collects more data, it’s critical to automate your DSR fulfillment processes.

Automating privacy request fulfillment increases privacy program efficiency, accuracy, and cost savings while creating a positive experience for consumers. Processing privacy requests quickly and without friction builds goodwill with consumers and employees by showing you care about their privacy rights.

Bottom Line:

Implementing automated request fulfillment increases customer trust and reduces business risk.

What is a Data Subject Request?

When an individual exercises their privacy rights and requests to access or modify their personal data being held by a company, they submit a Data Subject Request (DSR), or privacy request.

California data subjects, or requesters, have the right to access, delete, or correct their data, as well as opt out of the sharing or selling of their data to third parties. Data subjects are protected by law from unfair treatment or retaliation from businesses in response to privacy requests.

Product Spotlight:

Request Manager

Automatically track and fulfill privacy requests with Request Manager.

• Simplify DSR Fulfillment: Process requests in minutes, not days. Reduce the risk of human error and handle requests in a repeatable, scalable way.
• Automate Identity Verification: DataGrail’s Smart Verification uses pre-existing data to authenticate users, reduce request friction, and eliminate fraudulent DSRs.
• Keep Requests Organized: Keeping inbound requests organized is easy thanks to DataGrail’s user-friendly request forms. The forms funnel DSRs to automatically populate in your centralized Privacy Dashboard.

Enabling strong data privacy practices for your organization is a behavior problem. Teaching employees early and often about company privacy operations, how to spot privacy violations, data security threats, and more will ensure a privacy-centric culture throughout your organization.

Educated employees understand the potential consequences of a data breach or security incident and can take the appropriate preventative measures to ultimately reduce overall business risk.

What To Include in Staff Training

• Introduction to Data Privacy: Provide a foundational understanding of data privacy, its importance, and the potential consequences of privacy breaches.
• Data Protection Regulations: Educate employees on relevant regulations for your business like the CCPA, including the rights of individuals and organizational obligations.
• Identifying and Handling Sensitive Data: Teach employees to identify different types of sensitive data (e.g. personally identifiable information (PII), financial data, etc.) and explain the proper handling and storage procedures to ensure confidentiality and integrity.
• Security Best Practices: Cover essential security practices like strong password management, MFA, secure file sharing, and other security essentials
• Social Engineering Awareness: Raise awareness about social engineering tactics like phishing emails, impersonation attempts, or pretexting, and provide practical tips to help employees recognize and respond to these threats appropriately.