A privacy impact assessment is a process that is used to analyse the effects of a project or program on the privacy of a group of individuals.
The process of conducting a privacy impact assessment helps to identify the likely privacy risks. It also helps an organisation come up with mitigation strategies for any risk that might be experienced. The assessment is critical in addressing any privacy impacts a project might have before it commences.
A privacy impact assessment can also be used to;
- Check whether a proposed program complies with relevant laws and authority.
- Verify whether a proposed program impacts the privacy rights of individuals.
- Assist in making decisions on how to adjust a certain program to mitigate the privacy risks it brings about.
A PIA is an important part of any organisation’s program management and planning. It allows your organisation to continually plan, manage and update privacy challenges and risks as they continually evolve through the program’s life cycle.
Best practices for your PIA
Describe the project
Knowing the goal of the project can give context during the PIA process. A person can choose whichever method best suits them and find the most effective methods that achieve their goals while not restricting personal data or personal privacy. This will most likely be obtained from management documents, for example, the project brief or business case.
Identify and consult with stakeholders
External stakeholders often require the view of people whose private information is likely to affect projects. Internal stakeholders may find answers to queries describing the possible flows of information systems and governance structure within a specific organisation.
They can suggest possible ways to address such sensitive questions. Although extensive public consultation might lack value, it is possible to undertake targeted consultation through governmental, independent legislative bodies, advocacy groups, etc.
Conduct a threshold assessment
PIAs are useful when undertaking any project that requires updating methods for managing user data and modifying existing processes. However, no project will require this due to privacy concerns about information that could be collected from clients via this tool or through its services.
A threshold privacy assessment provide information on determining whether projects need a PIA. There are many tools available to understand privacy impacts on the operation of some projects. In general, it is proposed that there are no modifications to current data processing processes or practices.
Map the personal information flow
Next, it is important to explain if personal details were part of the project and how it would travel between agencies, systems, and processes. It’s not easy enough to document information flows across a network.
A business process diagram may assist users clarify how the system works. It’s important for people with personal information, not just those with medical histories and their contact details unless they are formally registered or otherwise notified.
Dealing with risk
Developing risk mapping helps prioritise risks according to the likelihood the risk materialises, as well as the seriousness of the consequences. Privacy should be integrated into other projects’ objectives as far as functionality cannot be excluded.
Applications are approved if the public policy in noncompliance is strong while private interests in compliance are greater. Privacy has to integrate within project objectives rather than being a compulsion.
Identify privacy impacts
The effect on private information can be negative (risks) and possibly positive. This practice will help identify risk mitigation while also uing the same techniques for identifying and maximising potential outcomes.
A security audit must take into account how an application has processed its user details and what steps have been taken to ensure that the information is collected securely.
Build PIA checkpoints into your project plan
Typically, plans may vary on scope or by changing their requirements with new tools that solve the problem. Incorporate PIA checks to assess if there is a substantial change in the project. If it has inserted the updated PIA, start repeating this process for any other impact needed.
Respond and review
If necessary, measures must be undertaken following recommendations given within the review and updating of the PIA, with the project being completed in compliance with existing PIA procedures.
It is essential to document everything the project manager or supervisory group agreed to and it may also be useful in preparing recommendations on how to follow them.
The recommendations are then integrated into a revised plan to help ensure the actions required in executing these recommendations are taken care of and reported.
Why undertaking a PIA is necessary
If the program you are planning to undertake has privacy implications like collecting, disclosing, or using personal information or is likely to conflict with the privacy act or existing information handling practices, it is importa to conduct a privacy impact assessment. This is regardless of whether the information you will be collecting will be new personal information or information that is already held by your company.
Each program has a different level of complexity, size, and nature. A privacy impact assessment is designed to work for any kind of program. However, more complex programs will require a comprehensive privacy impact assessment process. This will result in a detailed report. Simpler programs mean the PIA process will also be shorter.
A PIA is not mandatory under the community expectations or the government agencies. However, a PIA process can be vital when assessing information privacy principles under the PDP act.
Assessing the impact of a program on your privacy risks is not only about legal compliance. Your program may be legally compliant but people’s data may still get affected. This is how the process of conducting a PIA helps to identify privacy risks more broadly. It also shows your commitment to protecting people’s privacy and risk management.
PIA will help your company promote community awareness and boost public confidence and trust since the general public has been considered in the implementation of the program.
People care about how you handle their private and personal data. They are also most likely to engage with organisations that have great privacy practices. When you conduct a PIA, you will also raise privacy awareness within your company. This will ensure accountability to the program and affirm the importance of data privacy within your company.
You should conduct a PIA to benefit those individuals with who you collect their data and use it in your business process. This will mitigate the potential damage that may face your organisation or the individuals and all contracted service providers. You should conduct a PIA early enough in the design of the wanted program.
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