1) Conduct a Privacy audit
Organisations need to implement a privacy audit which evaluates the type of sensitive information held by an organisation. This sensitive information can refer to employees' personal details such as their tax file number or Medicare number and includes whether or not you have the rights to audit and access information, as well as the timely return of information when an agreement ends. Analyse each aspect of this process which includes the collection, retention, use, and disclosure of personal information and determine risk levels. In cases where an organisation uses a cloud provider, it is important to understand who the stakeholders are, what their roles and responsibilities include, and where data is located and replicated.
Ask yourself: is third party data simply stored or is it being mined for advertising and marketing purposes?
2) Data protection and privacy impact strategy
Ask yourself: what happens in the event of a data breach?
3) Create privacy policies and procedures
Develop policies and procedures that clearly state the importance of protecting sensitive information stored in-house or in the cloud which complies with the requirements of the Australian Privacy Principles (APPs). An organisation needs to take measureable steps to protect the personal information it holds from misuse. This includes mechanisms to protect and manage the information, including disaster recovery processes to protect against data loss. An organisation's legal advisor needs to fully understand the nature of both the cloud and privacy requirements and should be able to tailor the legal protections in your agreement.
Ask yourself: what are the privacy policies that your organisation needs? Understand your key areas of weakness so you can develop a plan to protect data.
4) Ensure accuracy and transparency of all personal information held
Personal information collected by an organisation needs to be accurate, complete, and up to date. Customers should have access to their information and make corrections if required. For instance, if an organisation holds a database which records the phone number and address of its customers, a process needs to be put in place which allows customers to change or update their details.
Ask yourself: when was the last time you updated your customer database?
5) Appoint a policy offer and train employees to mitigate security risks
Monitoring employees to ensure that privacy policies are applied will be very hard to manage on a daily basis. Transferring knowledge to your employees will identify weakness and help mitigate security risks. This is no simple task. Look at appointing a policy officer that trains employees and regularly monitors content and activity to prevent any violation.
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