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.
Do you know your data and processes?
In one engagement, we worked with a privacy officer who was sure that the all of the organization’s data subjects were from the US. As we proceeded through the assessment process we spoke to members of each of the individual business units, all of which supported the privacy official’s perception. A few weeks later, one of those business area interviewees shared that there actually was an EU-focused website. Another person shared that the organization’s human resources group provides support for the parent company’s employees around the world. The privacy officer was surprised.
At another engagement we met with an individual leading the development of a new international web site. It was the first time this company was going to actively sell outside of the US. It was a bit of a surprise to the privacy office.
Stay close to the business
A privacy office needs to stay on top of new uses of personal information, new applications, and new business processes. The privacy office is often viewed as impediment to meeting implementation deadlines, so the business areas may not be as transparent with the privacy office as you might like.
It is vital for members of the privacy office to spend time with the various business areas to establish a relationship. Even if you are not excited to work with a particular team, you need to engage them so they are comfortable coming to you to share their plans. Consider attending team meetings if you can. Become part of their planning process suggesting how things can be done as opposed to what cannot be done.
Be cautious with leadership messages
In both situations described above, the privacy office was unaware of what was being done within the business areas. In both cases, the privacy function was relatively new or the senior levels of the organization recognized it was time to update the program. Leadership’s focus in both cases was to be GDPR ready.
Getting leadership involved to endorse privacy activities is a wonderful thing. The message communicated could cause the unintentional behaviors. In these cases, the focus was on achieving GDPR compliance, as opposed to be transparent internally, so the business areas provided information to meet leadership’s goal.