As technology advances, the data privacy and personal data protection landscape has also evolved dramatically. That said, it has also become crucial for organisations to be well aware of the ever-evolving regulatory requirements so they can update their data protection practices and policies accordingly.
They need to also look into using tools like the GRC software to help sustain their data protection efforts and make their data protection management programme more effective.
What is Data Protection Management Programme?
Organisations that use, collect, and disclose personal data are required to create and implement practices and policies that are needed so an organisation can comply with the Personal Data Protection Act (PDPA). This can include adapting legal requirements into practices and policies.
This also includes using controls and monitoring mechanisms to ensure the processes and policies are implemented effectively. This also includes establishing an organisational culture of responsibility through awareness and training programmes. The Data Protection Management Programme is a four-step programme that is designed to create a strong data protection infrastructure.
Step #01: Governance and Risk Assessment
This includes the establishment of a governance structure that can define values and determine risks when it comes to organisational leaderships.
Step #02: Policy and Practices
This includes the development of data protection practices and data protection policies.
Step #03: Processes
This involves designing processes to operationalise the policy.
Step #04: Maintenance
This involves detailing steps to ensure data protection processes and policies are up-to-date.
Having a robust DPMP can help ensure an organisation can demonstrate data protection accountability. This can help provide confidence to the stakeholders and foster higher-trust relationships with business partners and customers for business competitiveness.
How to Sustain a Data Protection Management Programme
Sustaining a DPMP has three components: monitor, audit, and communication (MAC).
Monitor
Monitoring involves keeping track of the DPMP amongst the parties involved. This is carried out in two steps—one focused on learning while the other is focused on assessment.
Learning involves the creation of relevant data protection content and ensuring it is available to the individuals in the organisation. The mode of delivery can be through face-to-face classroom sessions or through e-learning.
In terms of assessment, the data protection officer (DPO) needs to ensure that information on the organisation’s personal data protection policies can be recalled when required. This is typically done by carrying out quizzes and tests.
Audit
Organisations need to carry out a yearly audit of its financial processes and statements. In the same manner, organisations that handle personal data should perform regular audits of their privacy or data protection programme to ensure they stay compliant. As part of the audit process, the organisation’s privacy procedures and policies should also factor in the current regulatory requirements.
The auditing process should also cover the policy documents, SOPs, and notices in visible areas. Other areas that are included in the audit process are administrative, technical, and physical procedures. The audit team will set the approach, objectives and the scope of work. Once the audit is complete, the findings are recorded and a report will be submitted for any corrective actions to be implemented.
Communication
It is crucial for organisations to effectively communicate and inform their employees about data protection policies, updates on data protection matters, and any amendments to the data protection laws. As soon as relevant updates have been sent, it is necessary to also keep track of who has read the information.
This will show regulators there is accountability and the organisation has a well-documented and systematic approach to communicating content and updates that are related to personal data protection.
