Centraleyes Privacy Framework (CPF)

What is the CPF?

The Centraleyes Privacy Framework (CPF) is a comprehensive compliance tool designed to help organizations adhere to the diverse privacy regulations that are individual to each state in the United States. As of now, these states are California, Colorado, Connecticut, Virginia, Utah, Washington, Nevada, New York, Massachusetts, Maine, Maryland, New Jersey, Illinois, Minnesota, Oregon, Rhode Island, Texas, and Wisconsin. The CPF provides a standardized set of controls and guidelines that align with the core principles of these state laws, making it easier for organizations to achieve compliance without needing to tailor their practices separately for each jurisdiction. By providing a unified set of controls, CPF simplifies the process of managing compliance with multiple state privacy laws. This framework is particularly useful for businesses operating in multiple states or those handling data from various jurisdictions, offering a streamlined approach to privacy management.

As privacy regulations become increasingly complex and varied, CPF addresses these challenges by standardizing compliance requirements. The framework is crafted to align with the core principles of most state privacy laws, ensuring that organizations can efficiently manage their privacy obligations without having to navigate each regulation separately.

What Topics Does the CPF Include?

CPF covers essential aspects of privacy regulation, reflecting the requirements of contemporary state laws. Key topics addressed include:

1. Consumer Rights
   • Right to Access: Consumers can request access to their personal data.
   • Right to Correction: Consumers can ask for corrections to inaccurate or incomplete data.
   • Right to Deletion: Consumers have the right to request the deletion of their data under certain conditions.
   • Right to Data Portability: Consumers can obtain their data in a portable format for transfer.
   • Right to Opt-Out: Consumers can opt out of the sale or sharing of their personal data.
2. Data Security Requirements
   • Data Protection Measures: Implement robust technical and administrative measures to safeguard personal data.
   • Data Encryption: Use encryption to secure data both in transit and at rest.
   • Access Controls: Restrict data access to authorized personnel only.
   • Incident Response: Develop a plan to respond to data breaches and security incidents.
3. Compliance with State Regulations
   • Data Processing Agreements: Ensure contracts with third parties comply with privacy standards.
   • Privacy Notices: Provide clear and comprehensive privacy notices to inform consumers.
   • Training and Awareness: Educate employees on privacy practices and regulatory requirements.

The Importance of CIS Controls

The CPF incorporates the Center for Internet Security (CIS) Controls, which are a set of best practices designed to enhance data security and privacy. According to the California Attorney General’s report, these controls define the fundamental measures organizations should take to protect data. Here’s a closer look at the CIS Controls:

1. Basic Controls
   • Inventory and Control of Hardware Assets: Track and manage all hardware devices within the organization.
   • Inventory and Control of Software Assets: Maintain an inventory of software applications to ensure they are properly managed.
2. Foundational Controls
   • Secure Configuration for Hardware and Software: Implement secure configurations for all hardware and software.
   • Continuous Vulnerability Management: Regularly identify and address vulnerabilities in systems and applications.
3. Organizational Controls
   • Access Control Management: Ensure only authorized users have access to data and systems.
   • Data Protection: Employ measures to protect sensitive data from unauthorized access and breaches.

The CIS Controls are essential for establishing a strong security posture and ensuring compliance with privacy requirements. By integrating these controls into your privacy framework, you can enhance data protection and reduce risk.

Policies and Procedures Relevant to Privacy

To support privacy compliance, organizations need to establish and maintain several key policies and procedures. CPF provides guidance on these essential documents, as well as templates for meeting privacy requirements, such as:

1. Record of Processing Activities (RoPA)
   • What is RoPA?: RoPA is a detailed record of all data processing activities within an organization. It includes information about the types of data processed, purposes of processing, and data retention periods.
   • Importance: Maintaining a RoPA helps organizations understand their data processing operations and ensures transparency and accountability.
2. Data Processing Agreement (DPA)
   • What is a DPA?: A DPA is a contract between a data controller and a data processor that outlines the obligations and responsibilities related to data protection.
   • Importance: A DPA ensures that third-party processors comply with privacy regulations and adhere to agreed-upon data protection standards.
3. Privacy Notice
   • What is a Privacy Notice?: A Privacy Notice is a document that informs consumers about how their data is collected, used, and shared by an organization.
   • Importance: Providing a clear and transparent Privacy Notice helps organizations build trust with consumers and ensures compliance with transparency requirements.
4. Data Protection Impact Assessment (DPIA)
   • What is DPIA?: A DPIA is an assessment process used to identify and mitigate risks associated with data processing activities. It evaluates the impact of data processing on individuals’ privacy.
   • Importance: Conducting a DPIA helps organizations proactively address privacy risks and ensure that data processing activities do not adversely affect individuals’ rights.

CPF provides top-of-the-line templates for these essential documents and the policies and procedures associated with privacy regulations, helping organizations efficiently develop and maintain their privacy policies and procedures.

Why Should You Use the CPF?

Adopting the Centraleyes Privacy Framework offers several compelling benefits:

1. Simplified Compliance
   • Unified Approach: CPF consolidates compliance requirements for multiple state privacy laws, making it easier to manage privacy obligations across different jurisdictions.
   • Efficiency: Streamline your compliance efforts with a single set of controls and guidelines.
2. Enhanced Privacy Protection
   • Comprehensive Coverage: Ensure that all necessary privacy and security measures are in place to protect consumer data.
   • Best Practices: Implement CIS Controls to adhere to industry best practices for data protection.
3. Reduced Risk
   • Mitigate Legal Risks: Avoid penalties and legal issues associated with non-compliance.
   • Protect Reputation: Build consumer trust and maintain a strong reputation by demonstrating a commitment to privacy.
4. Cost-Effective Solution
   • Consolidated Efforts: Save time and resources by using a single framework that meets multiple regulatory requirements.

By integrating the CPF into your compliance strategy, you can achieve efficient and effective management of state privacy regulations while ensuring robust protection for consumer data.

How do we achieve compliance?

​​Meeting state privacy and security compliance requirements with the Centraleyes Privacy Framework (CPF) involves a structured and streamlined approach facilitated by the Centraleyes Risk & Compliance Management platform.

Organizations start by assessing their privacy landscape and establishing clear guidelines for data management and protection. This process ensures alignment and commitment from leadership. During the planning phase, potential privacy risks are identified, and objectives for data handling are set, supported by appropriate resources, training, and communication strategies.

Centraleyes simplifies this process through its cloud-native platform, automating tasks related to risk management from data collection to analysis and remediation. Its user-friendly interfaces and smart questionnaires make risk assessments more efficient, while the automated Risk Register provides detailed, tailored information about organizational data risks. Centraleyes’ automated ticketing system streamlines task management, delegation, and tracking, ensuring accountability and prompt action.

By integrating Centraleyes into their privacy governance framework, organizations can achieve compliance, enhance their data protection measures, and foster continuous improvement in their privacy practices. This positions them to effectively manage privacy regulations and safeguard consumer data in a secure and responsible manner.