4 Easy Steps To Create Privacy Management Plan For Business
A privacy management plan is a document that identifies specific, measurable goals and targets that identify how you will implement the four steps outlined in the Framework. This template is designed to help you develop a privacy management plan for your entity. Which commitments you implement within each step, and who performs these, will depend upon your particular circumstances, including your entity’s size, resources and business model.
You may be able to adapt this template to include specific details around how you intend to implement each commitment. Alternatively, it could be appropriate to specify these details in a separate project plan, dependant on the size and scale of the relevant commitment.
Also read: PRIVACY MANAGEMENT PLAN
Step 1 — Embed: a culture of privacy that enables compliance
Creating a culture of privacy compliance within your organisation encourages team members to take responsibility for the businesses’ privacy obligations. This includes:
- implementing a privacy management plan that aligns with your businesses’ privacy obligations and processes;
- training your team about the importance of privacy and ensuring senior management is informed of any developments to the law; and
- assigning responsibility to team members so that it’s clear who is accountable for privacy, such as appointing a privacy officer.
|Adopt a ‘privacy by design’ approach|
|Assign key roles and responsibilities for privacy management|
|Assign staff responsibility for managing privacy|
|Create reporting mechanisms that ensure senior management are routinely informed about privacy issues|
|Ensure staff understand their privacy obligations and the roles|
Step 2 — Establish: robust and effective privacy practices, procedures and systems
Your business must implement procedures and practices for dealing with private information, including:
- ensure that the way you collect and handle the data of customers and employees complies; and
- create a data breach response plan to ensure that you have a strategy in place if a breach occurs.
|Keep information about your business’s personal information holdings (including the type of information you hold and where it is held) up to date|
|Develop and maintain processes around the handling of personal information prior to collection, while personal information is held and once it is no longer needed|
|Integrate privacy into staff training and induction processes|
|Implement risk management processes to identify, assess and manage privacy risks across the business|
|Establish processes for receiving and responding to privacy inquiries and complaints|
|Establish processes that allow individuals to promptly and easily access and correct their personal information|
|Create a data breach response plan|
Step 3 — Evaluate: your privacy practices, procedures and systems to ensure continued effectiveness
The plan should be subject to ongoing evaluation, involving:
- a regular review of your privacy management plan to monitor compliance and relevance; and
- feedback from customers and employees on your processes.
|Regularly monitor and review privacy processes, policies and notices|
|Document compliance with privacy obligations, including keeping records on privacy process reviews, breaches and complaints|
|Measure your performance against this privacy management plan|
|Create channels for staff and customers to provide feedback on privacy processes|
Step 4 — Enhance: your response to privacy issues
Your business should seek to amend and improve its processes to increase privacy and data security, by:
- accounting for the privacy implications of new technologies and software.
|Use the results of evaluations to make changes to practices, procedures and systems to improve privacy processes|
|Have your privacy processes externally assessed/audited to identify areas for improvement|
|Keep up to date with issues and developments in privacy law and changing legal obligations|
|Monitor and address new security risks and threats|
|Examine and address the privacy implications, risks and benefits of new technologies. Consider implementing privacy enhancing technologies that allow you to minimise and better manage the personal information you handle|
|Introduce initiatives that promote good privacy standards in your business practices|
|Participate in Privacy Awareness Week and other privacy events|
What to Include in Your Privacy Management Plan
Your plan should outline the measures that your business will put in place to comply. In other words, it should include your goals to avoid a data breach and build a culture of privacy compliance within your organisation.
Depending on the size and nature of your business, your plan may include:
- your commitment to transparently manage personal information;
- the contact information of the person responsible for your business’ privacy processes;
- your internal processes for educating your team of recent privacy developments;
- the actions your business will take if there is a data breach;
- mechanisms that allow for feedback from both your clients and your team; and
- your plans to continually monitor potential security threats.
Although your business is not legally required to have a plan, it is best practice to encourage customers’ and employees’ confidence in your processes. It published a template privacy management plan, which you can adapt to your business. This includes the four essential steps of a plan:
- evaluate; and
Also read: Privacy Management Plan