IAPP-GDPR Web Banners-300x250-FINAL

To truly understand the potential impacts and scope of an incident or privacy issue, you must track back to the root cause. Take time to ensure that you have identified the correct root cause and that you understand the downstream impacts the issue may have. For example, if correspondence has been sent to the wrong party the root cause could be several different things. It could be the result of human error—an employee printing the letter and manually mailing it to the wrong person; it could be driven by a recent change to the system that generates all letters that was not thoroughly tested, or it could have been a data processing error where the address was keyed incorrectly. Understanding the true root cause is critical in fixing this issue and preventing it from recurring in the future.

Once you have identified the root cause, then you need to develop a corrective action plan. The corrective action plan must correlate directly to the root cause that you have identified. For instance, if we take a look at our example in the case of human error where an employee mailed the letter to the wrong recipient, the employee would need to be coached and counseled on quality-checking processes or quality-checking processes may need to be established or enhanced. In the second scenario, driven by a recent change to the system that generates all letters that was not thoroughly tested, testing protocols and full regression testing processes may need to be established or enhanced to ensure that testing occurs end to end. Or, in the data processing scenario where the address was keyed incorrectly, the employee would need to be advised of the error and retrained on quality-checking processes or those processes expanded to prevent recurrence. Whatever the scenario is, make sure that you formally document the root cause of the issue and the corrective action plan, including the names of responsible parties and timelines.

In a situation where an issue or incident was caused by an employee, formally document any sanctions taken with that employee. The documentation of sanctions should include all levels of sanctions, anything from coaching or counseling up to termination. If the employee was coached or counseled on the error and retrained on the quality process, have the manager formally document that and store that information in a place where you can to get it if and when needed, such as the associate’s HR file. The documentation of the sanctions taken is not to be punitive to the employee but rather to make sure that the privacy office has access to this information. If you do not include it in the employees file, you run the risk of the manager leaving the company or losing the ability to find the documented sanctions when needed. Often if regulators receive a complaint about a privacy incident/issue, they want to see the related documentation, including how you addressed the situation to prevent it from happening again.

Taking the time to identify and document the proper root cause of an incident or privacy issue, creating a formal corrective action plan, and documenting sanctions will save you time and frustration if this information is needed to respond to a regulatory inquiry. Even if the full corrective action plan has not been completed, you can show that you are aware of the issue and that you are taking the proper steps to address the issue.  

Did you miss the first parts in this series? Click to find posts one, two , three, four and five and six.

Written By

Deidre Rodriguez, CIPP/US


If you want to comment on this post, you need to login.


Board of Directors

See the esteemed group of leaders shaping the future of the IAPP.

Contact Us

Need someone to talk to? We’re here for you.

IAPP Staff

Looking for someone specific? Visit the staff directory.

Learn more about the IAPP»

Daily Dashboard

The day’s top stories from around the world

Privacy Perspectives

Where the real conversations in privacy happen

The Privacy Advisor

Original reporting and feature articles on the latest privacy developments

Privacy Tracker

Alerts and legal analysis of legislative trends

Privacy Tech

Exploring the technology of privacy

Canada Dashboard Digest

A roundup of the top Canadian privacy news

Europe Data Protection Digest

A roundup of the top European data protection news

Asia-Pacific Dashboard Digest

A roundup of the top privacy news from the Asia-Pacific region

IAPP Westin Research Center

Original works. Groundbreaking research. Emerging scholars.

Advertise in IAPP Publications

Find out how to get your message in front the people you want to reach. Download a media kit now.

Get more News »

Find a KnowledgeNet Chapter Near You

Network and talk privacy at IAPP KnowledgeNet meetings, taking place worldwide.

Women Leading Privacy

Events, volunteer opportunities and more designed to help you give and get career support and expand your network.

IAPP Job Board

Looking for a new challenge, or need to hire your next privacy pro? The IAPP Job Board is the answer.

Join the Privacy List

Have ideas? Need advice? Subscribe to the Privacy List. It’s crowdsourcing, with an exceptional crowd.

Find more ways to Connect »

Find a Privacy Training Class

Two-day privacy training classes are held around the world. See the complete schedule now.

Online Privacy Training

Build your knowledge. The privacy know-how you need is just a click away.

The Training Post—Can’t-Miss Training Updates

Subscribe now to get the latest alerts on training opportunities around the world.

New Web Conferences Added!

See our list of upcoming web conferences. Just log on, listen in and learn!

Train Your Staff

Get your team up to speed on privacy by bringing IAPP training to your organization.

Learn more »

CIPP Certification

The global standard for the go-to person for privacy laws, regulations and frameworks

CIPM Certification

The first and only privacy certification for professionals who manage day-to-day operations

CIPT Certification

The industry benchmark for IT professionals worldwide to validate their knowledge of privacy requirements

Certify Your Staff

Find out how you can bring the world’s only globally recognized privacy certification to a group in your organization.

Learn more about IAPP certification »

Get Close-up

Looking for tools and info on a hot topic? Our close-up pages organize it for you in one easy-to-find place.

Where's Your DPA?

Our interactive DPA locator helps you find data protection authorities and summary of law by country.

IAPP Westin Research Center

See the latest original research from the IAPP Westin fellows.

Looking for Certification Study Resources?

Find out what you need to prepare for your exams

More Resources »

GDPR Comprehensive: Registration Open

New! Intensive two-day GDPR training led by the sharpest minds in the field. It's a can't-miss event.

The Congress Is Cancelled

The IAPP Europe Data Protection Congress 2015 is cancelled. Click through to learn more.

Sponsor an Event

Increase visibility for your organization—check out sponsorship opportunities today.

Exhibit at an Event

Put your brand in front of the largest gatherings of privacy pros in the world. Learn more.

More Conferences »

Become a Member

Start taking advantage of the many IAPP member benefits today

Corporate Members

See our list of high-profile corporate members—and find out why you should become one, too

Renew Your Membership

Don’t miss out for a minute—continue accessing your benefits

Join the IAPP»