While the CPRA was passed in 2020, it will not go into effect until January 2023. Most organizations are expected to ensure their data collection practices are in line with the law when it goes into effect. There’s no point in delaying the inevitable. If your organization hasn’t begun transforming and altering its data collection practices, it is high time to start.
Have a Data Transfer Mechanism and Strategy in Place
This is arguably the most sensitive part of any organization’s privacy management infrastructure. This is down to the fact that while an organization may have to comply with itself with a data protection regulation in one country to process and collect data on its residents, it may find having to balance out its practices to be able to transfer this data to another jurisdiction.
Moreover, nearly every data protection regulation has a stringent set of requirements that an organization must fulfill before it can transfer the data out of the jurisdiction in the first place.
Naturally, this can all become incredibly messy and escalate into a crisis unless you have a proper data transfer mechanism and strategy in place that takes into account every possible step that may hinder your compliance efforts.
Ultimately, the buck stops with the dev team and DevOps team, In this case, to ensure that whatever mechanism the organization ends up adopting is fully capable of transferring data securely across regulatory jurisdictions without leading to a breach of any statutes an organization is required to follow.
Some would argue that the entire philosophy of privacy management is built upon accountability. While various data protection regulations globally are meant to ensure all businesses follow a certain set of practices that reduce any chances of data breaches, true accountability comes from within.
The most practical method of ensuring such accountability is by maintaining a regular and up-to-date record of processing activities (RoPA). Again, this is something that most data protection regulations will require businesses to maintain anyway, with processing activities, data flows and categories of data subjects the most common items that need to be covered.
Similarly, make sure any third parties or vendors you work with have the relevant practices in place before going forward with any sort of data sharing, even if you have user consent to do so.