As privacy is a fundamental right, organizations must take appropriate steps to protect individuals' privacy. A Privacy Impact Assessment is a tool that organizations can use to manage privacy risks (PIA). In this blog post, we'll look at why conducting a PIA is important, when to do it, who is in charge of doing it, and how to do it.
A PIA is a risk management tool used to identify the actual or potential effects on an individual's privacy of a proposed or existing information system, technology, program, process, or other activity. Organizations can identify potential privacy risks and determine how to address them by conducting a PIA. The advantages of conducting a PIA include confirming the project's legal authority to collect, use, retain, and disclose personal information, demonstrating due diligence and evidence of compliance, promoting better decision-making and a privacy culture, improving institutional transparency and individual awareness, understanding, and trust of your institution's information management practises, and improving operational efficiencies.
To be effective, PIAs should be started early in project development or design. Privacy protection should not be an afterthought, and privacy risks should be considered throughout the project's lifecycle. Addressing privacy risks proactive during project design is faster, easier, and less expensive than retrofitting privacy protection requirements after your programme, process, or system has been implemented.
Each institution must determine who will coordinate and execute the PIA. Some institutions will have staff who are well-suited to conduct a PIA, while others may require the services of an outside specialist. Institutions must also determine who will review and approve the PIA and how the project should proceed to address identified privacy risks. An effective PIA will necessitate the consultation and participation of numerous individuals with specialized roles, expertise, and insight into the project.
The PIA process generally follows four key steps: preliminary analysis, project analysis, privacy analysis, and PIA report.
In the preliminary analysis, organizations examine the project to determine if it will involve the collection, use, retention, disclosure, security or disposal of personal information. If personal information is involved, organizations proceed with the PIA process.
In the project analysis, organizations collect specific information about the project, the key players and stakeholders, and the type of and manner in which personal information will be collected, used, retained, disclosed, secured, or disposed of.
In the privacy analysis, organizations use the information gathered in the previous step to identify FIPPA or MFIPPA requirements and potential risks and impacts to privacy, consider ways to reduce or eliminate the risks and impacts identified, and assess proposed solutions and their benefits.
Finally, in the PIA report, organizations obtain approval to proceed with recommended solutions, document their findings and chosen solutions, and ensure that the recommendations from the PIA are fully incorporated in the project plans and implemented.
Ultimately, conducting a PIA is an important tool for managing privacy risks associated with today's information management systems, programmes, and technological tools. Organizations must consider privacy risks early in project development or design and involve a variety of individuals with specialized roles, expertise, and insight into the project. Organizations can identify potential privacy risks and determine how to address them by conducting a PIA, promoting better decision-making and a privacy culture within the organization.
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Resources
Planning for Success: Privacy Impact Assessment Guide. (n.d.). Retrieved April 5, 2023, from https://www.ipc.on.ca/wp-content/uploads/2015/05/Planning-for-Success-PIA-Guide.pdf
Agency, C. R. (2023, March 30). Government of Canada. Privacy impact assessment summaries - Canada.ca. Retrieved April 5, 2023, from https://www.canada.ca/en/revenue-agency/services/about-canada-revenue-agency-cra/protecting-your-privacy/privacy-impact-assessment.html
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