PDOC-02

Do you conform with a specific industry-standard privacy framework (e.g., NIST Privacy Framework, GDPR, ISO 27701)?

Explanation

This question is asking whether your organization follows a recognized privacy framework that provides structured guidance for managing personal data and privacy risks. Privacy frameworks are standardized approaches that help organizations implement privacy controls, manage data protection, and comply with relevant laws. Why it's being asked: 1. To assess if your organization has a systematic approach to privacy rather than ad-hoc practices 2. To understand which specific standards guide your privacy practices 3. To evaluate if your privacy controls align with recognized best practices 4. To determine if you can meet the privacy requirements of clients in different jurisdictions Common privacy frameworks mentioned include: - NIST Privacy Framework: A voluntary tool developed by the US National Institute of Standards and Technology - GDPR (General Data Protection Regulation): The European Union's comprehensive privacy law - ISO 27701: An extension to ISO 27001 that adds privacy-specific requirements When answering this question, you should: 1. Clearly state which framework(s) you conform with 2. Mention any certifications or assessments that verify your conformance 3. If you don't follow a specific framework but have your own privacy program, explain its key elements 4. If applicable, note how your framework aligns with relevant regulations in your operating regions

Guidance

Standard privacy frameworks help organizations enhance data protection, mitigate privacy risks, and demonstrate compliance with appropriate industry and regulatory standards. This is particularly important when providing services in different jurisdictions.

Example Responses

Example Response 1

Yes, our organization conforms with multiple privacy frameworks to ensure comprehensive protection of personal data We are ISO 27701 certified as of January 2023, which extends our existing ISO 27001 information security management system to include privacy-specific controls We have also implemented the NIST Privacy Framework and maintain a documented mapping between our controls and its core functions Additionally, we have implemented controls necessary for GDPR compliance and undergo annual third-party assessments to verify our conformance with these frameworks Our privacy team conducts quarterly internal reviews to ensure ongoing compliance as frameworks evolve.

Example Response 2

Yes, our organization has implemented the NIST Privacy Framework as our primary privacy standard We have mapped our privacy controls to all core functions (Identify-P, Govern-P, Control-P, Communicate-P, and Protect-P) and conduct annual self-assessments against the framework While we are not formally certified against ISO 27701, we have incorporated many of its requirements into our privacy program For GDPR compliance, we maintain documentation of our processing activities, have implemented appropriate technical and organizational measures, and have appointed a Data Protection Officer We are currently working toward formal ISO 27701 certification with an expected completion date of Q3 2024.

Example Response 3

No, we do not currently conform with a specific industry-standard privacy framework Our privacy program was developed internally based on general best practices and specific requirements from our legal team We do implement various privacy controls including data minimization, purpose limitation, and access controls, but these are not formally mapped to frameworks like NIST Privacy Framework, GDPR, or ISO 27701 We recognize this as a gap in our privacy program and have initiated a project to adopt the NIST Privacy Framework within the next 12 months In the interim, we conduct annual privacy impact assessments on our key systems and have documented privacy policies that are reviewed annually by legal counsel.

Context

Tab: Privacy
Category: General Privacy