WHAT DOES A DATA PRIVACY OFFICER DO?
Published: MM DD, 2024 - The Data Privacy Officer develops all Data Protection and Privacy requirements in alignment with leading practices, international standards, and local regulations, cooperating with supervisory authorities on development and checks. This position coordinates across departments to document specific data protection and privacy requirements and ensures the implementation of approved rules for security devices related to Data Protection. This role monitors and documents compliance with data management policies, while providing consultations on encryption and addressing all data protection inquiries within legal timeframes.
A Review of Professional Skills and Functions for Data Privacy Officer
1. Data Privacy Officer Duties
- Data Inventory Management: Keeping the data inventory current as company activities change and evolve.
- Privacy Risk Assessment: Support the Chief Privacy Officer’s development of corporate-wide privacy risk assessments and mitigation plans.
- Regulatory Knowledge: Be well-versed in national and local regulatory requirements that cover private and healthcare sectors.
- Compliance Monitoring: Monitor compliance with program controls and demonstrate due diligence.
- Cross-Department Collaboration: Liaise with other departments through a collaborative and supportive approach to ensure privacy-related requirements have been met.
- Incident Review and Reporting: Review privacy incidents, breaches, and grievances, and report on recommendations upon the conclusion of an investigation.
- Notification Requirements: Collaborate with the Chief Privacy Officer to determine any member, client, or regulatory notification requirements.
- Documentation Management: Create and amend privacy and project documentation required for operational, clinical, or regulatory purposes, such as Information Management Agreements, Privacy Impact Assessments, and others.
- Annual Review Completion: Ensure the completion of Annual System reviews.
- Performance Indicator Monitoring: Create and monitor performance indicators to determine the effectiveness of privacy controls.
2. Data Privacy Officer Details
- Data Protection Evaluation: Evaluate the existing data protection framework and identify areas of non-compliance or partial compliance, rectifying any issues.
- Privacy Impact Assessment: Conduct a Privacy Impact Assessment (PIA) for all processes.
- Compliance Promotion: Promote a culture of data protection compliance across all units of the organization.
- Privacy by Design Assessment: Conduct Privacy by Design assessments (PDA) for all new projects, tools, and processes.
- Privacy Awareness Training: Participate in, develop, implement, and run a range of privacy awareness training and campaigns.
- Monitoring Checkpoints Application: Apply all needed monitoring checkpoints across all teams and functions.
- Privacy Technical Assessment: Conduct the necessary privacy technical assessment for all data breach cases.
- Vendor Assessment: Conduct the necessary vendor assessments during the onboarding stage.
- Data Protection Policy Implementation: Support the DPO in the implementation of the Data Protection Policy and the Data Protection Framework.
- Data Protection Culture Promotion: Promote a data protection culture within the company by providing advice and support on privacy issues to business teams and the offices.
3. Data Privacy Officer Responsibilities
- Privacy Governance Implementation: Implement measures and a privacy governance framework to manage data use in compliance with the GDPR, CCPA, and other applicable privacy regulations.
- Stakeholder Collaboration: Work with key internal stakeholders in the review of projects and related data to ensure compliance with data privacy laws, and where necessary, complete and advise on privacy impact assessments.
- Primary Contact for Privacy Queries: Serve as the primary point of contact for privacy-related queries in the business.
- Privacy Governance Review: Manage and conduct ongoing reviews of Interos' privacy governance framework and policies.
- Privacy Awareness Education: Assist in driving cross-functional organizational education of privacy awareness and proactive risk identification and assessment related to privacy, as well as other enterprise-wide risks.
- Policy Standardization: Set standards and review policies and procedures that meet the requirements under the GDPR and any localization requirements in regions of operation.
- Data Asset Management: Collaborate with the Technology, Product, and Customer Success groups to maintain records of all data assets and exports, and maintain a data security incident management plan to ensure timely remediation of incidents, including impact assessments, security breach response, complaints, claims, or notifications, and respond to subject access requests (SARs).
- Data Protection Impact Assessment Advisory: Advise on data protection impact assessments when required under Article 35 of the GDPR.
- Compliance Monitoring: Monitor compliance, including managing internal data protection activities, training data processing staff, and conducting internal auditing and monitoring.
4. Data Privacy Officer Job Summary
- Data Protection Development: Develop all Data Protection and Privacy requirements based on leading practices, international standards, and local regulatory frameworks, and cooperate with the supervisory authorities NDMO and NCA on Data Protection and Privacy requirements development or checks.
- Requirement Coordination: Coordinate with related departments to gather and document specific requirements regarding data protection and privacy.
- Rule Definition and Release: Define and release approved rules for Data Protection-related security devices to be shared and implemented by related departments.
- Policy Monitoring: Monitor the development, implementation, and compliance with data management policies and procedures, such as data classification and labeling.
- Documentation of Checks: Document the results of periodic data protection and privacy checks and share them with relevant stakeholders.
- Data Register Maintenance: Ensure that the data registers are maintained across all departments and that data elements are captured throughout the entire environment.
- Policy Implementation Monitoring: Monitor the implementation of rules and policies in tools (such as DLP or Guardium) regarding access to data, systems, and software.
- Consultation on Encryption: Provide consultation on encryption and cryptography mechanisms to support the implementation of data protection (in use, at rest, and in motion).
- Incident Documentation: Document the results of troubleshooting data protection incidents and mitigation actions taken upon escalation, in collaboration with Cybersecurity Intelligence & Defense.
- Customer Query Management: Ensure that departments address all queries from data subjects (customers) within legal frameworks and timeframes.
- Regulatory Compliance Follow-up: Follow up on changes in laws and regulatory frameworks and collaborate with Governance and Compliance to ensure compliance with Privacy frameworks by providing new recommendations in policies and check activities.
5. Data Privacy Officer Accountabilities
- Privacy Program Development: Build a strategic and comprehensive privacy program by working with senior management, security, and data governance.
- Privacy Framework Design: Design, implement, and maintain privacy frameworks, data protection risk assessments, and privacy incident response management.
- Privacy Leadership: Provide privacy leadership across the organization, supporting divisions to advise employees on obligations and promoting good privacy practices as a business enabler and a critical element of securing customers' futures.
- Legal Knowledge Maintenance: Maintain current knowledge of applicable federal and state privacy laws and accreditation.
- Breach Management: Manage all required breach determination and notification processes under OAIC requirements and applicable state requirements.
- Privacy Complaint Handling: Establish and administer a process for investigating and acting on privacy complaints.
- GDPR Compliance Maintenance: Maintain all the company's systems, controls, processes, tools, and documentation that enable all data processing activities to comply with GDPR and national data protection legislation in the EU countries in which it operates.
- Data Subject Request Management: Handle and respond to all data subject requests and maintain appropriate records of them.
- Privacy Documentation Drafting: Draft and review privacy notices and other non-contractual documents related to privacy.
- Policy Implementation: Implement the designed policies and procedures according to local data privacy requirements.
- Personal Data Breach Monitoring: Monitor and record all personal data breaches.