A compliance program usually follows the same logic as building new technology. Each program has a logical sequence of steps. Before proceeding to the next, the previous step must be complete. One depends on the other. Imagine you are developing a new AI in your company. Then divide your project into three main phases:
1. Define WHAT the AI must be able to do.
2. Define HOW how the AI should do it (create the code).
3. Test the demo and make final adjustments.
If the developer does not have all the information for their coding, they will not be able to execute it properly. Phase 2 depends on phase 1 to move forward.
GDPR Compliance Program Framework
Data Discovery & Data Classification
A GDPR compliance program is no different. The program needs to start with a Data Mapping of the company. It is the only way to understand how the company operates, what type of data it collects, and for what purpose. Then a Gap Analysis is conducted to assess what the company is doing right and what is missing. After this first phase, we can move on to the remediation phase with all the necessary information.
Understandably, business partners and contract negotiations can sometimes cause you to rush the process, but the main focus should be on the bigger picture. Your partners want to see you comply, or at least do your best to do so. Be honest with them! Tell them you are working on it and provide documents to prove your progress. In the long run, this is much better than submitting a revised document full of empty words.
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