2018 was a very eventful and active year for privacy professionals. As we come to the end, I have been discussing what plans are being put in place for 2019 with our clients. If their plans are any indication, 2019 will have privacy professionals busier than ever.
Not surprisingly, the implications of GDPR are continuing to resonate. While the focus has been on achieving compliance (and this will continue), GDPR has awakened organizational leadership that there is more to this privacy thing than just putting up a notice on a web site. You actually have to implement policies and procedures then verify they are implemented.
Preparing for CaCPA
Now along comes the California Consumer Privacy Act. While there are parallels to GDPR and other legislation, CaCPA puts new demands on many organizations. At a minimum, allowing California residents to opt-out of the selling of their personal information will put a strain on some IT teams and some departmental budgets.
Organizations are not only looking at CaCPA requirements, but are looking across all of the jurisdictions in which they operate to see what legal and regulatory requirements are coming into effect or are foreseen in the near future. Many are planning on an assessment of their privacy program against these requirements as well as industry best practices.
Emphasizing training & awareness
With the recognition that fines are only going to get larger, organizations are seeing an improvement on the return on investment for training their team members in privacy, Some organizations are looking to finance certifications for managers in privacy related roles such as HR, IT, and customer service. Others are simply looking to expand privacy training to occur more frequently (we recommend at least annually) and become more expansive.
I am also seeing more interest in the creation of awareness programs, informal activities that remind people about privacy issues between training events. Posters, lunch and learns, webinars, celebration of Data Privacy Day, videos, and some very creative approaches are all up for discussion.
Strengthening compliance assurance
There is also an increased recognition that it is not enough to just put policies and procedures in place, There is increased emphasis on verifying compliance within organizations as well as at their data processors. We have had discussions on audit, assessment, and attestation approaches to find the right fit to meet organizational goals.