Chapter 1: Starting a Compliance Program
1 Starting a compliance program When you set out to design and implement a data privacy compliance program, you face a number of threshold decisions and preparatory tasks, including the following: Putting a person or team in charge of data privacy law compliance Preparing a task list by identifying relevant facts, laws and requirements; defining priorities based on business objectives, enforcement risk exposure, and ease of compliance Executing the task list Working with internal stakeholders and outside advisors. 1.01 1.1 Taking charge 1.02 Someone needs to be in charge. If your business is a one-person sole proprietorship, then you are in charge. In larger organizations, however, there are typically a number of individual candidates or departments that could take charge of data privacy compliance, including lawyers, information technology staff, human resources and internal audit personnel. Each of these groups tends to have different approaches, strengths and limitations. Here are some factors to consider as you look for the right person or team: In-house attorneys in corporate legal departments usually take an advisory role and inform others in the organization what applicable laws require, including data privacy laws. Depending on company culture and individual styles, the legal department may advise proactively or upon request. Lawyers are trained to interpret and apply laws, including data privacy laws, but not all lawyers are technology-savvy or good project managers. Members of the information technology (IT) department are technology savvy, but may not find it easy to understand and apply laws. IT professionals are trained...
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