HECVAT Category
Privacy Policies and Procedures
Privacy Policies and Procedures covers controls and questions related to that domain. It outlines expectations institutions typically require from vendors. The category helps assess risk posture and operational maturity. It provides structure for consistent evaluation during security reviews.
Assessment Questions
Do you have a documented privacy management process?
This question is asking whether your organization has a formal, documented process for managing privacy-related matters. A privacy management process is a structured approach to handling personal data throughout its lifecycle within your organization.
Are privacy principles designed into the product lifecycle (i.e., privacy-by-design)?
This question is asking whether privacy considerations are built into your product from the beginning of its development lifecycle, rather than added as an afterthought. 'Privacy-by-design' is a framework developed by Ann Cavoukian (former Information and Privacy Commissioner of Ontario) that emphasizes proactive rather than reactive measures for protecting privacy.
Will you comply with applicable breach notification laws?
This question is asking whether your organization will adhere to laws and regulations that require notification of affected parties when a data breach occurs. Breach notification laws exist at various levels (state, federal, international) and typically mandate that organizations inform affected individuals, regulatory bodies, and sometimes the public when personal data has been compromised.
Will you comply with the institution's policies regarding user privacy and data protection?
This question is asking whether your organization will adhere to the institution's established policies for protecting user privacy and handling data.
Is your company subject to the laws and regulations of the institution's geographic region?
This question is asking whether your company must comply with the laws and regulations that apply in the geographic region where the institution (your potential client) operates.
Do you have a privacy awareness/training program?
This question is asking whether your organization has a formal program to educate employees about privacy principles, regulations, and best practices. A privacy awareness/training program is distinct from general security training and focuses specifically on how to properly handle, process, and protect personal and sensitive data.
Is privacy awareness training mandatory for all employees?
This question is asking whether your organization requires all employees to complete training specifically about privacy concepts, regulations, and best practices. Privacy awareness training is distinct from general security training and focuses on topics like handling personal data, understanding privacy regulations (such as GDPR, CCPA, HIPAA), recognizing privacy risks, and following proper procedures for data collection, storage, and sharing.
Is AI privacy and ethics awareness/training required for all employees who work with AI?
This question asks whether your organization requires specialized training on privacy and ethical considerations related to artificial intelligence for employees who work with AI systems.
Do you have any decision-making processes that are completely automated (i.e., there is no human involvement)?
This question is asking whether your organization has any fully automated decision-making processes where no human is involved in reviewing or approving the decision. Automated decision-making refers to situations where algorithms, AI, or other automated systems make decisions without human oversight that could impact users, customers, or data subjects.
Do you have a documented process for managing automated processing, including validations, monitoring, and data subject requests?
This question is asking whether your organization has formalized procedures for handling automated data processing activities. Automated processing refers to any operations performed on personal data by automated means without human intervention, such as algorithmic decision-making, automated profiling, or batch processing of data.
Do you have a documented policy for sharing information with law enforcement?
This question is asking whether your organization has a formal, written policy that outlines how you handle requests for information from law enforcement agencies (such as police, FBI, or other government investigative bodies).
Do you share any institutional data with law enforcement without a valid warrant or subpoena?
This question is asking whether your organization discloses customer or institutional data to law enforcement agencies without proper legal documentation (warrant or subpoena).
Does your incident response team include a privacy analyst/officer?
This question is asking whether your organization's incident response team (the group responsible for addressing security incidents) includes a dedicated privacy analyst or privacy officer.
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