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07-G: Privacy

This section assesses how your organization handles personal data and meets privacy obligations.

The questions focus on how you collect, use, share, and retain personal information; how you provide notice and obtain consent where required; how you protect data subjects’ rights (such as access, correction, or deletion); and how you manage cross-border transfers or third-party sharing. Overall, it confirms that privacy is governed by clear policies, aligned with applicable laws, and supported by operational controls.

Explanation: A privacy policy outlines how the company collects, uses, stores, and protects personal data, ensuring compliance with data protection laws.

Risks of Incorrect Answer: Potential legal penalties for failing to comply with privacy regulations.

Loss of client trust if data is mismanaged or mishandled.

Applicable Frameworks: GDPR (Art. 12-14): Requires clear and transparent privacy policies.

ISO 27001 (A.18.1.4): Ensures protection of privacy and personal data.

CCPA (Section 1798.100): Mandates privacy disclosures for businesses handling California residents' data.''

Explanation: A data retention policy ensures that data is stored only as long as necessary and securely disposed of when no longer required.

Risks of Incorrect Answer: Excessive data retention increases exposure to breaches and compliance violations.

Non-compliance with regulations mandating data minimization and retention limits.

Applicable Frameworks: ISO 27001 (A.8.3.2): Ensures secure disposal of media containing sensitive information.

GDPR (Art. 5(1)(e)): Requires data retention limits based on necessity.

HIPAA (164.310(d)(2)(i)): Mandates proper retention and destruction of health data.''

Explanation: Understanding how personal data is collected allows for assessing whether appropriate consent mechanisms and safeguards are in place.

Risks of Incorrect Answer: Unauthorized or non-compliant data collection may lead to regulatory fines.

Increased risk of misuse or breaches of sensitive information.

Applicable Frameworks: GDPR (Art. 6, 7): Requires lawful basis and consent for data collection.

CCPA (Section 1798.120): Grants consumers rights over the collection of personal data.'

Explanation: Secure data deletion ensures that sensitive information is not recoverable and complies with regulatory requirements for data lifecycle management.

Risks of Incorrect Answer: Residual sensitive data could be accessed or leaked, leading to reputational damage.

Non-compliance with regulations requiring secure data destruction.

Applicable Frameworks: ISO 27001 (A.11.2.7): Requires secure disposal of data and equipment.

GDPR (Art. 17): Grants the right to data erasure (right to be forgotten).

HIPAA (164.310(d)(2)(i)): Mandates secure data deletion for healthcare data

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Some or all of the services described in this engagement may not be available to certain clients, including those who have affiliations or relationships with audit firms or related entities.

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The information provided herein is of a general nature and is not intended to address the specific circumstances of any individual or entity. While we strive to offer accurate and up-to-date information, we cannot guarantee its accuracy at the time it is received or in the future. No action should be taken based solely on this information without seeking appropriate professional advice tailored to your particular situation. CRISP does not provide legal or tax advice.

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This information is not intended to constitute “written advice concerning one or more Federal tax matters” as defined by section 10.37(a)(2) of Treasury Department Circular 230.

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