Standard

Privacy Program

Creating a Culture of Privacy and Data Protection

The Privacy Program standard establishes fundamental privacy practices across our portfolio companies. By implementing key components of privacy policies and data protection measures, we significantly enhance our ability to protect customer and employee data, maintain regulatory compliance, and build trust with our stakeholders. This standard provides a foundation for continuously improving our privacy practices, adapting to evolving threats and regulatory landscapes. It aligns with industry best practices and frameworks, ensuring a comprehensive approach to data privacy across our organization, protect stakeholder information, ensure compliance with evolving privacy regulations, and enhance our data security posture.

Who: CEO, Finance Leader, IT Leader

Measurement: Assessment against capabilities and controls

Frequency: Annually

Key components include:

1. Privacy Policy: Utilize the corporate policy or develop a clear, accessible document outlining data handling practices and commitments to stakeholders.

2. Data Asset Inventory/Map: Develop a comprehensive overview of data assets, their locations, and flows within the organization.

3. Data Protection Policy: Utilize the corporate policy or develop guidelines and procedures for safeguarding sensitive information from unauthorized access or breaches.

4. Data Subject Request Handling Procedure: Develop a structured process for efficiently managing and fulfilling data subject rights requests.

5. Incident Response Plan: Define a strategy for addressing and mitigating potential data breaches or privacy incidents.

Discipline Experts

Rachel Pitts

VP, Compliance Counsel & Data Privacy

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