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Tag "Processing" returned 2 posts
Recently, I had dinner with a colleague that I had not seen in several years. Their company, a multinational with global operations, had undergone several changes in that time. When the dust settled, this friend had been tapped as “privacy manager”. Along with corporate counsel (part time for privacy), they decided that, even under GDPR, they did not need a Privacy / Data Protection Officer . Huh? Continue reading this post…
Posted on September 18, 2017 by Bob Siegel - No Comments
, Data protection
, Information protection
, Privacy Program Governance
Over the past several months, I have been taking a deeper dive into GDPR. I have found Article 6 on the legal basis for processing data particularly interesting. There is some discussion to be had for each company and how they will process data in a particular case, but I often hear that consent will be used. I have even heard arguments for consent as a catch-all for processing. This ignores the pitfalls that could come with the use of that certain legal basis. Continue reading this post…
Posted on August 14, 2017 by Ben Siegel - No Comments
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April 16, 2018
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July 9, 2018
Most of us have been wrapped up in GDPR preparations for several months. While there are many organizations "not quite there yet", many others have made great strides towards compliance. As we continue to do assessments for clients, both GDPR and General Privacy, I have been surprised at the frequency of the gap between a privacy official describing their organization's data subjects, information collected, and business processes with the reality of what is happening.
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Starting January 1, 2020, if you are a for-profit company doing business in California, you may have new data privacy compliance obligations. Specifically, California just enacted the California Consumer Privacy Act of 2018 (the country’s strictest data privacy law to date), placing new privacy mandates on certain businesses with respect to the personal information of consumers (defined as natural persons who are California residents). Many aspects of the new law smack of EU-GDPR influences, such as a new and improved (in other words, broader) definition of personal information and the inclusion of guaranteed consumer rights with respect to such personal information. If your business is already in compliance with the EU’s GDPR, the California law will be nothing new to you. For other businesses, however, you have 18 months to get with the program.
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