PRPO-13

Does your incident response team include a privacy analyst/officer?

Explanation

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. Why this matters: When security incidents occur, they often involve personal data or sensitive information. A privacy analyst/officer brings specialized expertise to ensure that privacy regulations (like GDPR, CCPA, HIPAA) are properly addressed during incident handling. Without this role, organizations might effectively address the technical aspects of an incident but fail to meet legal privacy notification requirements or properly assess privacy impacts. The guidance asks you to provide details about your incident response team's composition and specifically highlight the privacy role. This demonstrates that your organization takes a comprehensive approach to incident management that includes both security and privacy considerations. To best answer this question: 1. Clearly state whether you have a privacy analyst/officer on your incident response team 2. Describe the structure of your incident response team 3. Explain the privacy analyst/officer's role and responsibilities during incidents 4. Mention their qualifications or expertise if relevant 5. Describe how privacy considerations are integrated into your incident response process

Guidance

Provide an overview of your incident response team membership and its charge, highlighting the privacy analyst/officer.

Example Responses

Example Response 1

Yes, our incident response team includes a dedicated Privacy Officer Our incident response team consists of: Security Operations Lead, Network Security Engineer, Systems Administrator, Communications Manager, Legal Counsel, and our Privacy Officer The Privacy Officer is responsible for assessing all incidents for potential privacy impacts, determining notification requirements under relevant regulations (GDPR, CCPA, HIPAA, etc.), and ensuring proper documentation of privacy-related aspects Our incident response process includes specific steps for privacy impact assessment, which the Privacy Officer leads The team meets quarterly for tabletop exercises and operates under our formal Incident Response Plan, which was last updated in January 2023.

Example Response 2

Yes, we have integrated privacy expertise into our incident response team Our team follows a distributed model with core and extended members Core members include the CISO, Security Operations Manager, and IT Director who respond to all incidents Our extended team includes our Privacy Analyst who is engaged immediately for any incident potentially involving personal data The Privacy Analyst is certified in IAPP CIPP/US and CIPM, and is responsible for conducting privacy impact assessments, determining notification requirements, and ensuring compliance with privacy regulations during incident handling Our incident response process includes specific privacy assessment checkpoints, and our Privacy Analyst has authority to escalate privacy concerns directly to executive leadership.

Example Response 3

No, our current incident response team does not include a dedicated privacy analyst or officer Our team consists of our IT Director, Security Engineer, and Systems Administrator who handle all security incidents While we recognize the importance of privacy considerations during incident response, we currently address privacy matters through consultation with our legal department on an as-needed basis We are planning to enhance our approach by either training an existing team member in privacy compliance or hiring a dedicated privacy professional within the next fiscal year In the interim, we have documented procedures for when to engage legal counsel on privacy matters during incidents.

Context

Tab: Privacy
Category: Privacy Policies and Procedures