Privacy Impact Assessments are treated much too much as an assumption in (new European regulations’) privacy-anything these days. Yes, PIAs are a critical step, on the very critical path towards compliance in substance. Since when they aren’t done well if at all done with any true attention and intention, your compliance effort will fail, if not formally then in practice – with equal serious break-your-business high-probability risks.
First, this:
[Heaps upon Sea again indeed]
The point being; PIAs should be done with an actual interest in privacy (of stakeholders) protection. When done less than full-heartedly, the results have hardly any value. Because that would demonstrate one doesn’t understand the ethic imperatives of privacy protection in the first place. From which would follow all required (other) policies and measures would be half-hearted, ill-focused, and sloppily implemented ‘as well’. Which isn’t the stretch of reasoning you picked up on first reading this…
And then, a great many organisations don’t even start with PIAs, they just jump in at all angles and steps. With PIAs still being required, not full-heartedly carried out somewhere during or after the fact,where all the rest is implemented on assumptions that will not be met.
To which I would add: In the above, ‘you’ regards the ones in control (“governance”, to use that insult) at organisations that would have to be compliant. Not you the advisors/consultants, internally (in 2nd and 3rd LoDs) or externally, that push organisations. [Don’t! Just tell, record, and after the disaster ‘told you so’ them. There’s no use at all kicking this dead horse.]
But oh well, why am I writing this? Why am I hinting at ethics in your governance? That’s an oxymoron at your organization – do you claim to have the one or the other?
Feel free to contact if you’d like to remedy at least this part of your Privacy non-compliance…
