Isaca CDPSE - Certified Data Privacy Solutions Engineer

Following an established privacy framework is the most important step when developing an organizational data privacy program because it provides a structured and consistent approach to identify, assess, and manage privacy risks and compliance obligations. A privacy framework can also help to align the privacy program with the organization’s strategic goals, values, and culture, as well as to communicate and demonstrate the privacy program’s effectiveness to internal and external stakeholders. Some examples of established privacy frameworks are the NIST Privacy Framework, the ISO/IEC 27701:2019, and the AICPA Privacy Maturity Model.

Automated data discovery and classification tools provide continuous and systematic identification of data assets across the enterprise, ensuring accuracy and reducing manual errors. Internal updates (B) and departmental reporting (D) depend on human diligence; periodic manual audits (C) are time-bound and may miss changes between reviews.

“Automated discovery ensures a current and reliable data inventory, critical for privacy compliance.”

The most important consideration when writing an organization’s privacy policy is to align the statements to the organizational practices, because this will help ensure that the policy is accurate, consistent, and transparent. A privacy policy is a document that explains how the organization collects, uses, discloses, and protects personal data from its customers, employees, partners, and other stakeholders. A privacy policy should reflect the actual data processing activities and privacy measures of the organization, as well as comply with the applicable laws and regulations. A privacy policy that is not aligned with the organizational practices may lead to confusion, mistrust, or legal liability12.

A privacy audit is a systematic and independent examination of an organization’s privacy policies, procedures, practices, and controls to assess their compliance with applicable laws, regulations, standards, and best practices. A privacy audit may result in various outputs, such as findings, recommendations, observations, or opinions. Among the options given, the output that is most likely to trigger remedial action is the identification of deficiencies in how personal data is shared with third parties. This is because such deficiencies may pose significant risks to the privacy and security of the data subjects, as well as to the reputation and legal liability of the organization. Remedial action may include implementing contractual safeguards, technical measures, or organizational changes to ensure that third parties respect and protect the personal data they receive from the organization.

The proportionality of the data collected for the intended purpose is the most important privacy consideration when developing a contact tracing application. This means that the application should only collect the minimum amount of personal data necessary to achieve the specific and legitimate purpose of preventing and controlling the spread of COVID-191. The application should also ensure that the data collected are relevant, adequate, and not excessive in relation to the purpose2. The application should avoid collecting or processing any data that are not essential for the purpose, such as location data, biometric data, or health data unrelated to COVID-193. The application should also respect the data minimization principle, which requires that the data are kept for no longer than necessary for the purpose4. References:

European Data Protection Board Guidelines 04/2020 on the use of location data and contact tracing tools in the context of the COVID-19 outbreak

Article 5(1)© of the General Data Protection Regulation (GDPR)

Article 29 Data Protection Working Party Opinion 04/2017 on the Proposed Regulation for the ePrivacy Regulation

Article 5(1)(e) of the GDPR

The primary consideration to ensure control of remote access is aligned to the privacy policy is that access is only granted to authorized users. This means that the organization should implement and enforce policies and procedures to identify, authenticate, and authorize users who need to access personal data remotely, such as employees, contractors, or service providers. The organization should also define and communicate the roles and responsibilities of remote users, and the terms and conditions of remote access, such as the purpose, scope, duration, and security measures. By granting access only to authorized users, the organization can protect data privacy by preventing unauthorized or unnecessary access, use, disclosure, or transfer of personal data. References: : CDPSE Review Manual (Digital Version), page 107

Any organization collecting information about EU residents is required to operate with transparency in collecting and using their personal information. Chapter III of the GDPR defines eight data subject rights that have become foundational for other privacy regulations around the world:

Right to access personal data. Data subjects can access the data collected on them.

One of the privacy requirements related to the rights of data subjects is the right to access, which means that individuals have the right to obtain a copy of their personal data, as well as information about how their data is processed, by whom, for what purposes, and for how long. To meet this requirement, an organization’s technology stack should incorporate features that allow individuals to have direct access to their data, such as self-service portals, dashboards, or applications. This way, individuals can exercise their right to access without relying on intermediaries or manual processes, which can be inefficient, error-prone, or insecure. References: : CDPSE Review Manual (Digital Version), page 137

API keys are codes that are used to identify and authenticate an application or user when accessing an API. API keys could be stored insecurely, such as in plain text, in public repositories, or in unencrypted files. This could expose the API keys to unauthorized access, theft, or misuse by malicious actors, who could then access the API and the data it contains. This could result in data breaches, privacy violations, fraud, or other damages.