Are you thinking of starting a startup and wondering how to build your startup data privacy policy? Privacy policies are essential to start a business that processes the personal data of different users and stakeholders.
Here are some steps for you on how to build a startup privacy policy.
1. Hire a data privacy officer:
The first thing is that you have to appoint a data privacy officer in your organization responsible for data privacy matters. That person should know the subject matter with some legal and IT expertise. The general privacy regulation needs a data privacy officer for some specific processing activities.
For example, if you start a health data on a massive scale, The DPO suggests the organization with some data privacy matters, representing and serving as a connection between the company, third parties, and data privacy agencies.
Following the best practices, it is suggested to appoint a DPO even though appointing a person is not always required by law.
2. Explore the data life cycle:
Analyzing your data life cycle is the next step you need to take. The Data life cycle includes how data is collected, stored, processed, and deleted. It would help if you understood how data processing principles apply for the correct processing of data.
You have to create a chart to analyze your company’s data life cycle from data collection to data deleting. Understanding the above helps you measure the risks at the time of data processing and determine the security measures to prevent and minimize the risks.
3. Study information notices:
Controllers are needed to provide the information under GDPR to data owners about processing their data. Like purpose and legal basis of processing, assigning to whom data should be transferred, data owners’ rights, among others.
You can make the availability of an information policy to the data owners in two levels; one is an information notice provided when data has been collected, and the other one is a privacy policy made available to the data owners.
Also, GDPR needs companies to have a registry of processing activities that includes specific information. You can decide the level of aggregation or segregation of your data required for your activity with the guidance of your data privacy officer.
4. Conduct risk analysis:
It’s essential to conduct a prior identification and assessment of risks, which involves processing data for natural persons’ rights and freedoms. So that you can understand which security measures you have to implement.
For example, a startup company uses an online application platform to register and to update their data by the applicants. Even though the authentication method is weak, the startup can determine a low risk of confidentiality loss. It also considers the economic damage as a part of the risk assessments for the data subjects. And their application documents are publicly known now.
Once you define the security measures like updating computers, encrypting the data, security copies, and many can be implemented internally.
5. Study subject data rights:
It would help if you implemented a protocol as a part of your data privacy policy to follow the event that a data owner drills any of the rights guaranteed under the GDPR. GDPR requires security branches to notify the data privacy agency in 72 hours. And controllers should implement an incident or data breach response internal mechanism for some instances to the data owners. It allows them to react on time and within the legal requirements for the situations that arise. You have to implement a cookies policy if your startup has a website.
We hope you found this startup privacy policy overview with some main content of a data privacy policy useful. Appoint a data privacy policy officer if you want to know the complete information.
