GDPR Readiness: Creating a Data Privacy Plan

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The Data Privacy Plan is the best way an organization can document and enforce the privacy of personal information they hold. It puts in place procedures and guidance for how to properly handle data, respond to information requests, and deal with unexpected incidents or breaches. It contains information that applies to the day-to-day work of employees, as well as higher-level policies and guiding principles that apply to the company as a whole. The Data Privacy Plan is one of the best ways for an organization to become privacy compliant.

Learning Objectives

After you complete this course, you will be able to:

  • Explain what a data privacy plan will include
  • Know the important terminology and legislation regarding data privacy
  • Map the flow of data in an organization visually
  • Understand and write an information request procedure
  • Develop an internal data handling procedure
  • Understand and write a data security policy
  • Understand and write a personal data protection policy
  • Adapt your current client privacy policy
  • Develop a data breach procedure
  • Decide on training solutions for data privacy
  • Know the other necessary pieces of the data privacy plan
  • Help your organization write, implement, and review a data privacy plan

You will spend the first part of the day getting to know participants and discussing what will take place during the workshop. Students will also have an opportunity to identify their personal learning objectives.

Writing a Data Privacy Plan

A data privacy plan is the best way for an organization to document and enforce the privacy of the personal information they hold. The data privacy plan is comprised of a series of policies and procedures that govern the privacy practices within an organization. In this session, students will learn about the elements of a data privacy plan.

Privacy Awareness

A general understand of data privacy principles and law is needed to effectively create data privacy policies. Here, we cover some data privacy terminology, and the GDPR regulation.

Data Mapping

Before you can start creating privacy procedures and policies, you need to understand the flow of data within your organization. A data map is a clear, visual way to represent this information. This lesson goes over how to create an effective data map.

Information Request Procedure

When an individual contacts your organization in relation to their personal information, it is important to have an effective process to respond to these requests in a timely way.  In this lesson we will develop a general information request procedure and learn about the details required for a complete information request procedure.

Internal Data Procedures

The data handled by an organization should be governed by a set of internal rules. Data must be kept accurate, retained on a schedule, and properly deleted when appropriate. There also needs to be a process in place to monitor the implementation of these procedures by employees. In this lesson students will develop a set of internal data procedures.

Data Security Policy

Good data security is essential, both on an organizational and day-to-day operational level, to protect personal data. It is important to have a variety of security safeguards in place and documented. In this session we will consider the security measures in place at your organization and develop a data security policy.

Personal Data Protection Policy

The cornerstone document of the data privacy plan is the data protection policy, which outlines general staff guidelines around data privacy, proper data storage expectations, and specific responsibilities for privacy. Students will learn about the contents of a personal data protection policy, and develop their own.

Client Privacy Policy

The client privacy policy is designed to inform customers and external individuals of the organization’s privacy practices. It outlines what personal information is being collected, how it will be used, who it is being shared with, and what security measures are in place.  Questions a good privacy policy should answer are covered here, and students will adapt their own privacy policy.

Data Breach Procedure

A data breach is an unlikely, but serious occurrence. A procedure should be in place to ensure a structured and appropriate response to such an incident. Students will write a data breach procedure.


An effective training program will ensure that each employee in an organization receives the information they need to maintain proper data privacy within the scope of their work. Learners will brainstorm privacy training topics, and develop potential training methods for their workplace.

Other Necessary Pieces

The data privacy plan also requires supporting documents including Data Processing Agreements/Addenda (DPAs), Data Processing Impact Assessments (DPIAs), and contact information for the appropriate supervising authorities. In this final lesson, additional pieces to the data privacy plan including DPAs, DPIAs, and the supervising authorities are covered.


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