Roadmap for Building an Efficient Global Privacy Program: Organizational Structure

Whether PE sponsors are just starting to build out their privacy programs or revisiting more mature programs in the context of a dynamic legal and regulatory environment, they all should ensure their programs are proactive and sustainable. This article series walks through the steps involved in building an efficient global privacy program, with commentary from lead privacy officers at VMware, Zillow, Yahoo, Toyota Financial Services and Johnson Controls. The journey starts with an understanding of organizational structure, including where privacy sits; roles and responsibilities of the team; common reporting arrangements; and coordination with other business units. Subsequent articles in the series will address the scope and components of a privacy program; implementation approaches, including use of frameworks and automation tools; and ways to assess, maintain and update the program. See “Not Just GDPR: Examining the Other European Privacy Laws” (Mar. 10, 2020); and “How the GDPR Will Affect Private Funds’ Use of Alternative Data” (Jun. 14, 2018).

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