Putting your organisation in a defenisible position

HewardMills with its multilingual team of experienced data protection professionals provides available Data Protection Office (DPO) support for multinational companies.

So a defensible position is putting your organisation in a place where if a regulator were to come and ask any questions regarding any complaints a data subject has or in relation to any breach the organisation has gone through, that you are able to produce and justify your position as it stands.

So I would say the four steps to producing your organisation in a defensible position:
The first is Corporate Governance. It's important to ensure that there is an escalation of risks through the organisation's Corporate Governance structure and that the Data Protection risks are being escalated to the senior management team when and if needed.
The second being Privacy Operations. It's very important to ensure that you've got your core Data Protection documents. So for example your RoPA (Records of Processing Activities) is in place and obviously also your DPIA (Data Protection Impact Assessment), and on the base of that as well ensure that these documents are ever agreed and also continuously updated when need to be. We also recommended that privacy operations that, cyber security is looked at, and that there are safeguards in place to protect your organisation.
The third is Policies and Procedures. It's extremely important to make sure that these documents are in place for Data Protection documents, and also the procedures to accompany the policies are in place, and most importantly, is to ensure that the policies and procedures are being operationalized through the organisation. So you are indeed doing and implementing what is in the court documents.
And then last but absolutely not least is training. It's important to ensure that there's a training programme and the organisation helps in the socialization of the infection throughout the organisation and also has an important impact on the company culture..

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