Safe Harbor Framework - Comprehensive Certification Process
Riskpro’s US-EU Safe Harbor Privacy Assessment follows a comprehensive review of the organisation’s privacy policy, procedures and compliance requirements. We ensure that the company is compliant with the 7 principles required by US Department of Commerce, along with additional requirements outlined in the FAQs.
Data Collection Procedures – Riskpro reviews the data privacy practices for the website along with public disclosure of privacy policy. We understand what information you collect, how it is used, to whom is it transferred in the course of normal business and many more checks.
At the end of the engagement, we provide a comprehensive gap analysis report along with recommendation to address the gap. We help companies to get self certified by developing their policies and procedures as well. AS per the DMA.org website, your policy should address the following.
Data Analysis
Analyze data intake flows, data uses, and transfers to third parties
Notice to Customers
- Determine to whom, and when, notices must be given;
- Assure notices are drafted accurately and are given at all appropriate times and places; and Determine manner in which notice is made publicly available
Opt-out/Opt-in
Provide consumers with the opportunity to opt-out or opt-in depending on the nature of the data. Set-up appropriate procedures to respect consumers’ opt-out/opt-in requests particularly with respect to consumers’ requests to not be approached for direct marketing (i.e., in-house suppression system.) Opting-out should not require consumers to incur any fee or expense beyond a first-class stamp or phone callOnward Transfer
Determine the need for contracts with respect to the transfer of information to third partiesAccess
Set-up procedures to allow customers the ability to access their personal information and the ability to correct it where it is inaccurateSecurity
Set-up procedures to ensure that customer’s personal information is protected and secureData Integrity
Set-up procedures to ensure that the customer’s personal information is reliable, accurate, complete, current and used for its intended purposesEnforcement
- Refer consumers to your customer service department or other in-house dispute handling program to address their data privacy complaints; and
- Utilize the DMA Safe Harbor Program as the required independent third-party dispute resolution mechanism to address any unresolved in-house consumer data privacy complaints.
Assessment
Establish an annual compliance review process by adhering to either: - An internal self-assessment compliance review – you need to develop procedures for periodic objective reviews of compliance with your privacy policy and complaint handling; or
- An outside third-party assessment review/audit
Training
- Assure all personnel receive general training in your safe harbor privacy policy. More extensive training should be provided to personnel who have access to or deal with the data; and
- Modify employee/personnel policies to provide for training and discipline for failure to follow your policy
