The ‘Privacy StrategyandProcesses’ layer within the DSCI Privacy Framework (DPF©) is designed to support the development of:

A structured privacy governance model

Visibility over personal information and processing flows (A)

Organizational privacy policies and operational processes (B)

Mechanisms for understanding and addressing regulatory obligations (C)

While Information Usage and Access (D) and Personal Information Security (E) are important aspects of privacy management, they fall under different layers such as ‘Data Life Cycle Management’ and ‘Security Controls’ respectively, rather than the StrategyandProcesses layer.

The consultants appointed by XYZ to design and implement the enterprise wide privacy program conducted a visibility exercise. This exercise was meant to capture the current state of Personal Information (PI) flows within the organization, identify any gaps between existing security controls/practices and intended enterprise-wide PI practices. The visibility exercise also included mapping the legal obligations of the organization in protecting PI across different jurisdictions where its operations were spread. Though this exercise seemed adequate to start with, some gaps in terms of meeting the requirements of EU GDPR were noticed during course of implementation.

Firstly, though the visibility exercise covered all channels through which PI would flow in and out of an organization - like email accounts, websites and physical storage locations etc., it did not cover every element of PI such as Social Security numbers and financial data. Moreover, there was no comprehensive assessment on the technical feasibility and costs associated with implementing additional measures for protecting this information. This could have been done in order to ensure that any new systems or processes introduced met the technical requirements of GDPR.

Additionally, there were certain gaps in terms of external service providers who are also responsible for ensuring compliance with GDPR while processing/storing personal data on behalf of XYZ. Though XYZ had ensured that all its existing contracts contained provisions regarding compliance with legal requirements related to privacy and confidentiality, it did not carry out any due diligence exercise to ascertain whether these third-party service providers had adequate security practices in place to comply with GDPR regulations.

Lastly, the visibility exercise did not cover all the legal obligations of XYZ in terms of compliance with GDPR. For instance, it did not consider any potential liabilities arising from data breaches and the process for dealing with such eventualities. Nor was any process put in place to ensure that appropriate technical and organizational measures were taken to protect PI as required by GDPR.

Thus though the visibility exercise carried out by XYZ consultants seemed adequate at first glance, there were several gaps identified in terms of meeting EU’s GDPR requirements. These gaps could have been addressed through a more comprehensive assessment and must be taken care of if XYZ has to realize its full potential in Europe. As GDPR is now firmly in place across the continent, companies cannot ignore its regulations and must take necessary action to ensure compliance.

This includes making sure that every element of PI is taken into consideration while designing an enterprise-wide privacy program, due diligence with regards to external service providers who process/store data on behalf of XYZ, and establishing a comprehensive legal framework for dealing with any potential liabilities arising from data breaches.
In short, if XYZ does not address these gaps effectively, it may find itself in a vulnerable position in terms of protecting personal information as required by applicable laws. It will also be at risk of facing significant fines or other penalties.

Under the “Visibility over Personal Information (VPI)” practice area of the DSCI Privacy Framework, the first and foundational step in any privacy implementation is to:

“Create an inventory of business processes and associated data elements involving personal information.”

This baseline mapping ensures that organizations understand what data is processed, where it resides, and how it flows across systems and third parties. This forms the basis for subsequent governance, risk assessment, and compliance alignment.

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The layer “Information Usage, Access, Monitoring and Training” in the DSCI Privacy Framework includes:

Raising awareness on privacy principles

Conducting periodic training and education programs

Monitoring usage of information and enforcing accountability

This layer plays a vital role in ensuring that privacy-related roles, risks, and procedures are communicated clearly across the organization.

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The DPF’s “Regulatory Compliance Intelligence (RCI)” practice area is focused on identifying and mapping applicable legal and compliance requirements to the specific data elements across business processes. This enables organizations to operationalize compliance obligations by linking them directly with the data they manage.

RCI helps ensure that every data flow or processing activity has a mapped legal basis and complies with jurisdictional requirements.

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All the listed options (A, B, and C) are legitimate objectives of the “Visibility over Personal Information (VPI)” practice area. The VPI layer emphasizes:

Comprehensive inventorying and mapping of personal data across systems

Aligning data operations with privacy risks and business goals

Categorizing data to manage consent, retention, and sharing

Therefore, none of these options are incorrect or outside the scope of VPI.

The concept of "Privacy by Design" is a core principle emphasized in the DSCI Privacy Framework (DPF©) and DSCI Assessment Framework for Privacy (DAF-P©). This principle requires that privacy be integrated into the design specifications and architecture of IT systems and business processes, right from the start of the development process rather than being added later as an afterthought.

The DSCI Privacy Framework states:

"Privacy by Design is a proactive approach that embeds privacy into the design and operation of IT systems, networked infrastructure, and business practices. It aims to ensure that privacy is built into the system by default, thereby preventing privacy-invasive events before they happen."

This ensures data protection is foundational to system architecture and not merely a compliance requirement added later. This proactive method mitigates risks and enhances user trust by safeguarding personal information through preventive measures rather than reactive ones.