Phone: 07740 818036
Email: jlg@leatongray.com
The Accountability principle is at the heart of the Privacy Practice External DPO services. When the ICO investigates an organisation their first requirement is to challenge compliance through the review of copies of the Accountability documentation and any demonstration of how the policies and procedures contained within them have been implemented. The DPO service therefore emphasises the review, analysis and support of such documentation, and supports the effective operationalisation of them.
Ad-hoc advice to the business is central to the support provided by the external DPO service. This may be used in an operational manner supporting the business implement Privacy by Design or Default or supporting a DPIA on a new product or service. However, it can also be the mechanism to provide strategic advice or support on the development of new thinking as the regulatory picture becomes clearer.
In a fast-changing privacy world it is important that a business is both up to date with the existing regulatory regime and aware of the challenges that are around the corner. Regulation and consumers are moving fast in countries across the world, an independent DPO is part of the response to that environment.
Specific policies could be written or rewritten as the environment or the business changes. A regular programme supporting the review of existing policies and procedures can be created. DPIAs can be conducted independently by the Privacy Practice or an in-house DPIA can be supported or reviewed
Training can be created for all staff, or key groups of staff, for example developers. If training is already undertaken validation of the materials can be conducted.
A key reporting requirement of the GDPR is the provision of information from the DPO to the highest levels of management in an organisation. An annual report would be created using accountability documentation to ensure the Board of the business has an accurate and up to date picture of Data Protection compliance across the organisation.
Providing advice during, and in the immediate aftermath, of a data breach. The coordination of compliance, corporate HQ, press and PR, IT, information security and affected operational units. Advice is also provided on appropriate interactions with the Information Commissioner’s Office.
Reviewing the preparedness of the company’s systems designed to cope with a data breach. Particular emphasis is placed on the preparation undertaken by the likely key players inside the company and the coordination between them. A range of scenario rehearsals can be created from a “close-to-real-time” test of systems, through to a simple hypothetical test.
The Privacy Practice advocates the creation of Integrated Privacy Systems that embed Privacy and Data Protection compliance into the operations of a business. Such a compliant system can be designed “from the bottom up” or as an addition to existing mechanisms. Traditional compliance models can also be created to a client’s requirements.
As Privacy and Data Protection become more significant to regulators, boards and the public at large, it is becoming increasingly important for companies to integrate privacy into their strategic thinking. We help companies take the costs of Data Compliance and see how their strategy can make Privacy a profit centre.