PIMS Governance
Establish the privacy governance structure - forum, decision rights, escalation path and reporting into leadership - and define how it interacts with security governance rather than duplicating it.
Privacy Accountability
Assign accountability for privacy outcomes across business functions, define the privacy function’s mandate and independence, and record how accountability is exercised and evidenced.
PII Controller / Processor Model
Determine, per processing activity, whether the organization acts as controller, joint controller or processor, and derive the different obligation sets that follow. Getting this wrong invalidates everything downstream.
Personal Information Lifecycle
Map personal information from collection through use, sharing, storage, archival and disposal, identifying the systems and parties involved at each stage.
Processing Inventory
Build a maintained record of processing activities covering purpose, categories of data and data principals, recipients, transfers, retention and basis - structured so it can be kept current rather than rebuilt annually.
Privacy Risk Methodology
Define how privacy risk to individuals is assessed - distinct from risk to the organization - with criteria, thresholds and the point at which risk must be escalated or processing reconsidered.
Privacy Impact Processes
Implement a triggered impact assessment process integrated into project, product and procurement workflows so assessments happen before processing starts.
Data Principal / Subject Rights
Build the operational capability to receive, verify, action and respond to rights requests within required timelines, including how requests are located across systems and how responses are recorded.
Processor Governance
Establish due diligence, contractual privacy terms, sub-processor control, transfer safeguards and ongoing oversight for every third party processing personal information on your behalf.
Privacy Evidence Architecture
Define what record demonstrates each privacy control operated - consent records, rights request logs, assessment outputs, deletion confirmations - with retention and ownership specified.
Monitoring & Improvement
Run privacy metrics, internal audit, management review and corrective action so the PIMS is maintained and improved rather than left to decay after implementation.