OV-LGA-002 Privacy Officer/Privacy Compliance Manager

Provides leadership, management, direction, or development and advocacy so the organization may effectively conduct cybersecurity work.

Provides legally sound advice and recommendations to leadership and staff on a variety of relevant topics within the pertinent subject domain. Advocates legal and policy changes, and makes a case on behalf of client via a wide range of written and oral work products, including legal briefs and proceedings.

Develops and oversees privacy compliance program and privacy program staff, supporting privacy compliance, governance/policy, and incident response needs of privacy and security executives and their teams.

Knowledges 13

Code	Description	Work Roles
K0001	Knowledge of computer networking concepts and protocols, and network security methodologies.	52
K0002	Knowledge of risk management processes (e.g., methods for assessing and mitigating risk).	52
K0003	Knowledge of laws, regulations, policies, and ethics as they relate to cybersecurity and privacy.	52
K0004	Knowledge of cybersecurity and privacy principles.	52
K0005	Knowledge of cyber threats and vulnerabilities.	52
K0006	Knowledge of specific operational impacts of cybersecurity lapses.	52
K0008	Knowledge of applicable business processes and operations of customer organizations.	5
K0066	Knowledge of Privacy Impact Assessments.	6
K0168	Knowledge of applicable laws, statutes (e.g., in Titles 10, 18, 32, 50 in U.S. Code), Presidential Directives, executive branch guidelines, and/or administrative/criminal legal guidelines and procedures.	11
K0612	Knowledge of what constitutes a “threat” to a network.	8
K0613	Knowledge of who the organization’s operational planners are, how and where they can be contacted, and what are their expectations.	2
K0614	Knowledge of wireless technologies (e.g., cellular, satellite, GSM) to include the basic structure, architecture, and design of modern wireless communications systems.	7
K0615	Knowledge of privacy disclosure statements based on current laws.	2

Skills 3

Code	Description	Work Roles
S0354	Skill in creating policies that reflect the business’s core privacy objectives.	1
S0355	Skill in negotiating vendor agreements and evaluating vendor privacy practices.	1
S0356	Skill in communicating with all levels of management including Board members (e.g., interpersonal skills, approachability, effective listening skills, appropriate use of style and language for the audience).	4

Abilities 12

Code	Description	Work Roles
A0024	Ability to develop clear directions and instructional materials.	3
A0033	Ability to develop policy, plans, and strategy in compliance with laws, regulations, policies, and standards in support of organizational cyber activities.	5
A0034	Ability to develop, update, and/or maintain standard operating procedures (SOPs).	3
A0104	Ability to select the appropriate implant to achieve operational goals.	2
A0105	Ability to tailor technical and planning information to a customer’s level of understanding.	7
A0110	Ability to monitor advancements in information privacy laws to ensure organizational adaptation and compliance.	1
A0111	Ability to work across departments and business units to implement organization’s privacy principles and programs, and align privacy objectives with security objectives.	3
A0112	Ability to monitor advancements in information privacy technologies to ensure organizational adaptation and compliance.	4
A0113	Ability to determine whether a security incident violates a privacy principle or legal standard requiring specific legal action.	1
A0114	Ability to develop or procure curriculum that speaks to the topic at the appropriate level for the target.	4
A0115	Ability to work across departments and business units to implement organization’s privacy principles and programs, and align privacy objectives with security objectives.	2
A0125	Ability to author a privacy disclosure statement based on current laws.	1

Tasks 73

Code	Description	Work Roles
T0381	Present technical information to technical and nontechnical audiences.	3
T0384	Promote awareness of cyber policy and strategy as appropriate among management and ensure sound principles are reflected in the organization's mission, vision, and goals.	3
T0478	Provide guidance on laws, regulations, policies, standards, or procedures to management, personnel, or clients.	2
T0003	Advise senior management (e.g., Chief Information Officer [CIO]) on risk levels and security posture.	3
T0004	Advise senior management (e.g., CIO) on cost/benefit analysis of information security programs, policies, processes, systems, and elements.	5
T0029	Conduct functional and connectivity testing to ensure continuing operability.	2
T0032	Conduct Privacy Impact Assessments (PIAs) of the application’s security design for the appropriate security controls, which protect the confidentiality and integrity of Personally Identifiable Information (PII).	2
T0066	Develop and maintain strategic plans.	3
T0098	Evaluate contracts to ensure compliance with funding, legal, and program requirements.	2
T0099	Evaluate cost/benefit, economic, and risk analysis in decision-making process.	4
T0131	Interpret and apply laws, regulations, policies, standards, or procedures to specific issues.	2
T0133	Interpret patterns of noncompliance to determine their impact on levels of risk and/or overall effectiveness of the enterprise’s cybersecurity program.	2
T0188	Prepare audit reports that identify technical and procedural findings, and provide recommended remediation strategies/solutions.	2
T0861	Work with the general counsel, external affairs and businesses to ensure both existing and new services comply with privacy and data security obligations.	1
T0862	Work with legal counsel and management, key departments and committees to ensure the organization has and maintains appropriate privacy and confidentiality consent, authorization forms and information notices and materials reflecting current organization and legal practices and requirements.	1
T0863	Coordinate with the appropriate regulating bodies to ensure that programs, policies and procedures involving civil rights, civil liberties and privacy considerations are addressed in an integrated and comprehensive manner.	1
T0864	Liaise with regulatory and accrediting bodies.	1
T0865	Work with external affairs to develop relationships with regulators and other government officials responsible for privacy and data security issues.	1
T0866	Maintain current knowledge of applicable federal and state privacy laws and accreditation standards, and monitor advancements in information privacy technologies to ensure organizational adaptation and compliance.	1
T0867	Ensure all processing and/or databases are registered with the local privacy/data protection authorities where required.	1
T0868	Work with business teams and senior management to ensure awareness of “best practices” on privacy and data security issues.	1
T0869	Work with organization senior management to establish an organization-wide Privacy Oversight Committee	1
T0870	Serve in a leadership role for Privacy Oversight Committee activities	1
T0871	Collaborate on cyber privacy and security policies and procedures	2
T0872	Collaborate with cybersecurity personnel on the security risk assessment process to address privacy compliance and risk mitigation	2
T0873	Interface with Senior Management to develop strategic plans for the collection, use and sharing of information in a manner that maximizes its value while complying with applicable privacy regulations	1
T0874	Provide strategic guidance to corporate officers regarding information resources and technology	1
T0875	Assist the Security Officer with the development and implementation of an information infrastructure	1
T0876	Coordinate with the Corporate Compliance Officer regarding procedures for documenting and reporting self-disclosures of any evidence of privacy violations.	1
T0877	Work cooperatively with applicable organization units in overseeing consumer information access rights	1
T0878	Serve as the information privacy liaison for users of technology systems	1
T0879	Act as a liaison to the information systems department	1
T0880	Develop privacy training materials and other communications to increase employee understanding of company privacy policies, data handling practices and procedures and legal obligations	1
T0881	Oversee, direct, deliver or ensure delivery of initial privacy training and orientation to all employees, volunteers, contractors, alliances, business associates and other appropriate third parties	1
T0882	Conduct on-going privacy training and awareness activities	1
T0883	Work with external affairs to develop relationships with consumer organizations and other NGOs with an interest in privacy and data security issues—and to manage company participation in public events related to privacy and data security	1
T0884	Work with organization administration, legal counsel and other related parties to represent the organization’s information privacy interests with external parties, including government bodies, which undertake to adopt or amend privacy legislation, regulation or standard.	1
T0885	Report on a periodic basis regarding the status of the privacy program to the Board, CEO or other responsible individual or committee	1
T0886	Work with External Affairs to respond to press and other inquiries regarding concern over consumer and employee data	1
T0887	Provide leadership for the organization’s privacy program	1
T0888	Direct and oversee privacy specialists and coordinate privacy and data security programs with senior executives globally to ensure consistency across the organization	1
T0889	Ensure compliance with privacy practices and consistent application of sanctions for failure to comply with privacy policies for all individuals in the organization’s workforce, extended workforce and for all business associates in cooperation with Human Resources, the information security officer, administration and legal counsel as applicable	1
T0890	Develop appropriate sanctions for failure to comply with the corporate privacy policies and procedures	1
T0891	Resolve allegations of noncompliance with the corporate privacy policies or notice of information practices	1
T0892	Develop and coordinate a risk management and compliance framework for privacy	1
T0893	Undertake a comprehensive review of the company’s data and privacy projects and ensure that they are consistent with corporate privacy and data security goals and policies.	1
T0894	Develop and manage enterprise-wide procedures to ensure the development of new products and services is consistent with company privacy policies and legal obligations	1
T0895	Establish a process for receiving, documenting, tracking, investigating and acting on all complaints concerning the organization’s privacy policies and procedures	1
T0896	Establish with management and operations a mechanism to track access to protected health information, within the purview of the organization and as required by law and to allow qualified individuals to review or receive a report on such activity	1
T0897	Provide leadership in the planning, design and evaluation of privacy and security related projects	1
T0898	Establish an internal privacy audit program	1
T0899	Periodically revise the privacy program considering changes in laws, regulatory or company policy	1
T0900	Provide development guidance and assist in the identification, implementation and maintenance of organization information privacy policies and procedures in coordination with organization management and administration and legal counsel	1
T0901	Assure that the use of technologies maintains, and does not erode, privacy protections on use, collection and disclosure of personal information	1
T0902	Monitor systems development and operations for security and privacy compliance	1
T0903	Conduct privacy impact assessments of proposed rules on the privacy of personal information, including the type of personal information collected and the number of people affected	1
T0904	Conduct periodic information privacy impact assessments and ongoing compliance monitoring activities in coordination with the organization’s other compliance and operational assessment functions	1
T0905	Review all system-related information security plans to ensure alignment between security and privacy practices	1
T0906	Work with all organization personnel involved with any aspect of release of protected information to ensure coordination with the organization’s policies, procedures and legal requirements	1
T0907	Account for and administer individual requests for release or disclosure of personal and/or protected information	1
T0908	Develop and manage procedures for vetting and auditing vendors for compliance with the privacy and data security policies and legal requirements	1
T0909	Participate in the implementation and ongoing compliance monitoring of all trading partner and business associate agreements, to ensure all privacy concerns, requirements and responsibilities are addressed	1
T0910	Act as, or work with, counsel relating to business partner contracts	1
T0911	Mitigate effects of a use or disclosure of personal information by employees or business partners	1
T0912	Develop and apply corrective action procedures	1
T0913	Administer action on all complaints concerning the organization’s privacy policies and procedures in coordination and collaboration with other similar functions and, when necessary, legal counsel	1
T0914	Support the organization’s privacy compliance program, working closely with the Privacy Officer, Chief Information Security Officer, and other business leaders to ensure compliance with federal and state privacy laws and regulations	1
T0915	Identify and correct potential company compliance gaps and/or areas of risk to ensure full compliance with privacy regulations	1
T0916	Manage privacy incidents and breaches in conjunction with the Privacy Officer, Chief Information Security Officer, legal counsel and the business units	1
T0917	Coordinate with the Chief Information Security Officer to ensure alignment between security and privacy practices	1
T0918	Establish, implement and maintains organization-wide policies and procedures to comply with privacy regulations	1
T0919	Ensure that the company maintains appropriate privacy and confidentiality notices, consent and authorization forms, and materials	1
T0930	Establish a risk management strategy for the organization that includes a determination of risk tolerance.	1