STEP-1 UNDERSTAND THE ORGANIZATION’S DATA PROCESSING ACTIVITIES in Privacy Program

Conducting comprehensive review of the organization’s data processing activities: 

What type of personal data does the organization collect? (customer, employee or other sensitives information) How is personal data processed, stored and shared within the company Who has access to personal data, what are the policies and procedures for managing access? What third party service provider does the organization use and how do they handle the personal data? 

By Understanding the organization’s data processing activities, we can identify privacy risk and develop strategies to mitigate them. 

STEP-2 CREATE AND DEVELOP PRIVACY POLICY 

Develop a privacy policy that outlines the company’s commitment to data privacy and explains how personal data is collected, used, and protected. For example, the policy might include: 

A statement of the company’s commitment to privacy and data protection. 

• An explanation of the types of personal data that the company collects, and the purposes for which it is collected.  

• An outline of the company’s data protection practices, such as encryption, access controls, and data retention policies.  

• An explanation of data subject rights, such as the right to access and correct personal data, and the process for submitting data subject requests.  

• By developing a privacy policy, you can communicate the company’s privacy practices to stakeholders and build trust with customers, employees, and other partners. 

STEP-3 ESTABLISH A GOVERNANCE STRUCTURE 

Establish a governance structure that defines roles and responsibilities for managing data privacy. For example, you might: 

Create a data protection officer (DPO) role to oversee the company’s privacy program and serve as a point of contact for data subject requests.  

• Develop a privacy committee to review privacy policies and practices, identify privacy risks, and provide guidance on privacy matters.  

• Assign data privacy responsibilities to relevant departments, such as IT, legal, and HR. 

By establishing a governance structure, you can ensure that privacy responsibilities are clearly defined and integrated into the company’s operations. 

STEP-4 IMPLEMENT PRIVACY CONTROL in Privacy Program  

Implement privacy controls that mitigate privacy risks identified during your review of the company’s data processing activities. 

Implement data encryption to protect sensitive data from unauthorized access.  

• Develop access controls to limit access to personal data to only those employees who need it. 
• Develop data retention policies to ensure that personal data is not kept for longer than necessary.

By implementing privacy controls, you can reduce the risk of data breaches and demonstrate the company’s commitment to data privacy. 

STEP-5 TRAIN EMPLOYEE 

Develop a training program to educate employees on the company’s data privacy policies and procedures. 

• develop a privacy awareness program to educate employees on the importance of data privacy and the impact of privacy breaches.  

• Provide training on how to recognize and report privacy incidents.  

• Develop policies and procedures for responding to privacy incidents and provide training on these procedures. 

Step -6 Conduct Regular Assessment 

Conduct regular assessments to evaluate the effectiveness of the company’s privacy program and identify areas for improvement. 

• Conduct privacy impact assessments (PIAs) for new projects to identify privacy risks and develop strategies to mitigate them.  

• Conduct regular audits of data processing activities to ensure compliance with privacy policies and procedures.  

• Monitor data subject requests to ensure that they are handled in a timely and effective manner. 

By conducting regular assessments, you can identify privacy risks and develop strategies to mitigate them and ensure that the company’s privacy program is effective and up to date. 

Step-7 Maintain Compliance with Privacy Law and Regulation 

As a privacy professional, it is important to stay up to date with the latest privacy laws and regulations, such as the General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA). and also UU PDP from Indonesia,  You should review these laws and regulations and ensure that the company is in compliance with them. 

• Conduct a gap analysis to identify areas where the company’s privacy program falls short of legal requirements.  

• Develop strategies to address any gaps identified in the gap analysis.  

• Develop procedures for handling data subject requests and ensuring compliance with data subject rights under applicable privacy laws 

By maintaining compliance with privacy laws and regulations, you can reduce the risk of legal penalties and build trust with customers and partners. 

STEP-8 COMMUNICATE WITH STAKEHOLDERS 

It is important to communicate with stakeholders, such as customers, employees, and partners, about the company’s privacy practices. This can help build trust and demonstrate the company’s commitment to data privacy. 

Publish the company’s privacy policy on the website and make it easily accessible to customers and partners.  

• Develop a privacy notice that explains how personal data is collected and used in specific contexts, such as in marketing or recruiting.  

• Develop a process for responding to privacy inquiries and complaints from customers and partners. 

By communicating with stakeholders about the company’s privacy practices, you can build trust and demonstrate a commitment to data privacy. 

STEP-9 COLLABORATE WITH OTHER DEPARTMENTS 

Privacy is not just the responsibility of the privacy team – it requires collaboration across the entire organization and you should collaborate with other departments, such as legal, IT, and HR, to ensure that privacy considerations are integrated into all aspects of the company’s operations. 

• Work with the legal department to ensure that contracts with third-party service providers include appropriate privacy protections.  

• Work with the IT department to ensure that privacy controls are integrated into the company’s technology infrastructure.  

• Work with the HR department to ensure that employee data is handled in a manner consistent with the company’s privacy policies. 

By collaborating with other departments, you can ensure that privacy considerations are integrated into all aspects of the company’s operations, reducing the risk of privacy breaches and demonstrating a commitment to data privacy. 

Establishing a privacy program is not a one-time task, it is an ongoing commitment to protecting personal data, ensuring legal compliance, and building trust with stakeholders and also by following these nine steps, your organization can create a privacy framework that not only meets global data protection standards like GDPR and ISO/IEC 27701 but also supports sustainable business growth and operational transparency. A strong privacy program is more than just compliance it’s a competitive advantage in today’s data-driven world. 

If your organization hasn’t adopted ISO/IEC 27701, now is the perfect time to begin  

Contact the CBQA Global team at +62 8118468777 or [click here to register] for expert guidance and tailored solutions. With the right approach, your organization can significantly enhance integrity, build trust, and strengthen information security across all operations.