Privacy Program Framework and Metrics
A privacy program framework operationalizes controls and should begin with a privacy mission statement/vision aligned to the organization. Building it involves developing, implementing, and measuring the framework, with compliance and broader privacy metrics.
An appropriate framework helps achieve compliance, supports business commitments, and can be a competitive advantage by reflecting the value placed on protecting personal data. The steps are: develop the framework, implement it, and ensure appropriate metrics. Before development, the organization lays groundwork with a privacy mission statement and/or vision aligned to its overall purpose; baking in ethics motivates trustworthy relationships over mere fine-avoidance.
- Develop: create privacy policies/procedures/standards/guidelines and define program activities (inventories, flows, classifications, PIAs, education, monitoring, incident response, audits, complaint handling)
- Implement: communicate to stakeholders; understand applicable laws (territorial, sectoral, penalties, agency authority); review data-sharing, vendor, and affiliate agreements
- Metrics: identify audience, define reporting sources, define oversight metrics, identify collection points
Compliance metrics: data subject requests, third-party disclosures, incidents, employees trained, PIA metrics, risk indicators. Beyond compliance: privacy program ROI, business resilience, program maturity, trend analysis, resource utilization.