The most important consideration when establishing a data privacy program is defining the organization's role as a controller or processor. These roles, as outlined in privacy regulations such as the General Data Protection Regulation (GDPR), determine the responsibilities regarding the handling of personal data. A controller is responsible for determining the purpose and means of data processing, while a processor acts on behalf of the controller. This distinction is crucial for compliance with data privacy laws.
* Reporting structure for the data privacy officer is important, but it is a secondary consideration compared to legal roles.
* Request process for data subject access is essential for compliance but still depends on the organization's role as controller or processor.
* Physical location of the company can affect jurisdiction, but the role as controller or processor has a broader and more immediate impact.