CRAFTY LEARNS
Privacy for non-privacy lawyers
Market trends, practical problems, and their solutions
Facilitated by Alvarez & Marsal:
- Samita Patel, Senior Director (samita.patel@alvarezandmarsal.com)
- Sam Lowe, Director (sam.lowe@alvarezandmarsal.com)
1. Understand the data flows:
- What personal data is involved?
- Whose personal data is it?
- Where does it come from, where is it stored and where does it go?
- What parties are involved and what are their roles?
- How long is it kept for?
2. Consider the privacy principles:
- Make sure processing is lawful, fair, and transparent
- Have specific, explicit and legitimate purposes for personal data use (and do not use for other incompatible purposes)
- Only use personal data that is adequate, relevant, and necessary
- Keep personal data accurate and up-to-date
- Do not keep personal data longer than is necessary
- Put in place appropriate organisational and technical measures according to the processing risk
- Be able to demonstrate compliance
3. Manage the risk and expectations:
- For individuals and maintaining their rights
- For your organisation
- For wider stakeholders: shareholders, business partners, regulators
4. Think about responses:
- Ad-hoc measures
- Policy, procedures and processes
- Roles and responsibilities
- Culture and awareness
5. And remember these are risk-based rules:
- What is proportionate considering the risk
- What are industry practices and commercial realities
- What are competing rights and obligations
- Who should own risk approval and acceptance
If you want to learn more about this topic, here are some additional resources:
- Reach out to the Alvarez & Marsal team