I first became aware of Malcolm Crompton, CIPP/US, after seeing him speak at an IAPP conference several years ago. I was impressed with his passion for privacy and the warm way in which he engaged the audience. Crompton transitioned from being the Australian privacy commissioner, where he helped push for the creation of privacy laws, to becoming the managing director of a consultancy where he assists entities with complying with those same privacy laws. Crompton’s passion for privacy and warm, engaging style can be felt in his new book,Privacy Governance: A Guide to Privacy Risk and Opportunity for Directors and Boards, which is an update to Privacy and Boards: What You Don’t Know Can Hurt You.
In this new book, Crompton focuses his guidance toward company directors and boards, the importance of privacy compliance and how to address it. Far too often, privacy compliance is left to the practitioners within an organization, while those in the boardroom look to remain at arm’s distance from the important work of building an effective privacy compliance program.
The book starts with an introduction to privacy, which provides a historical look at the development of privacy principles across different jurisdictions, leading to the creation of the Australian Privacy Act of 1988 (Privacy Act). The introduction goes on to describe how the Privacy Act evolved and impacted how organizations should treat personal information. The introduction does a good job of providing a baseline understanding for readers who are new to privacy.
As the book continues, Crompton guides the reader through a description of each of the Australian Privacy Principles and how they apply to organizations. He provides insight into how businesses, directors and customers can be negatively impacted when an organization fails to comply with privacy legislation via fines, lawsuits, loss of customers and decreases in market valuation.
Crompton describes the importance of incorporating the tenets of Privacy by Design and privacy impact assessments into an entity’s project management processes. He stresses that privacy should be integral to an entity’s existing change and project-management processes. Crompton provides meaningful advice to directors indicating that they are accountable for ensuring privacy governance, increasing privacy awareness, ensuring an effective privacy strategy is in place and validating privacy compliance via regular audits.
The book ends with a set of checklists that directors can use to get an understanding of the state of their privacy management practices as well as their compliance with the Australian Privacy Principles. While the book provides a lot of the right questions to ask, it stops short of expressing the appropriate responses or what to do when the proper response isn’t provided for a question.
Throughout the book, Crompton speaks with the voice of authority as someone who has been in the trenches with companies helping them to navigate the privacy requirements mandated by legislation. This book is a must-read for company directors and boards who want to become serious about privacy compliance.
JC Cannon, CIPP/US, CIPP/IT, is a 15-year veteran of Microsoft with 11 of those years focused on privacy. He currently works as the advertising privacy manager for Microsoft’s Online Services Division where he performs privacy reviews of all new advertising products and services. He also monitors external privacy activities from regulators, researchers, industry and competitors and develops action plans for product, policy and marketing teams. He works on privacy policies, standards and external inquiries. Cannon represents Microsoft on the W3C Tracking Protection Working Group, the Network Advertising Initiative organization, the IAB: Advertising Technology Advisory Board and numerous privacy events. He is the author of Privacy: What Developers and IT Professionals Should Know and contributed to the books Writing Secure Code and Windows Security Resource Kit. He is also the author of The Euclidian science fiction books.