The Office of the Privacy Commissioner of Bermuda
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Week 1: Feb 5, 2024
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Activity: CEO Endorsement Letter Available
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Resource: Blog Post: What is a privacy programme?
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Week 2: Feb 12, 2024
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Activity: Designate a Privacy Officer (PO), Monitor privacy compliance, foster a culture of privacy.
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Resource: Blog Post: What is a Privacy Officer?
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Week 3: Feb 19, 2024
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Activity: Conduct all staff training on Privacy basics.
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Tool: Privacy & PIPA
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Event: Coming in March 2024! PIPA Unveiled
Week 4: Feb 26, 2024
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Activity: Create a list of business units.
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Tool: Setting up a Privacy Committee form
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Resource: How Investing in a Privacy Program Pays Off
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Event: Global Connections
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Week 5: Mar 4, 2024
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Activity: Set up interviews with each member of your Privacy Committee.
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Tool: Interview Guide
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Resource: Mid-Atlantic Privacy: Responsibility, Collaboration, and Creativity + Bermuda's Pink Sandbox
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Event: PIPA Unveiled Fireside Chat
Week 6: Mar 11, 2024
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Activity: Determine how PIPA affects each area of your business.
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Resource: PIPA/GDPR Crosswalk
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Event: Bermuda Risk Summit
Week 7: Mar 18, 2024
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Activity: Begin Data Mapping
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Tool: Mid Atlantic Privacy: Interoperability, or Why Bermuda is not an island.
Week 8: Apr 1, 2024
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Activity: Each member of the privacy committee takes 15 min to identify the information life cycle & "flow" for their unit.
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Tool: PrivCom Q2 Checklist
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Resource: Responsibility & Compliance
Week 9: Apr 8, 2024
Activity: Identify the purposes for which you use Personal Information?
Tool: PrivCom Checklist
Resource: Purpose Limitation
Event: Commissioner White visits IAPP Global Summit 2024
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Week 10: Apr 15, 2024
Activity: Review the meaning of 'Sensitive Personal Information'.
Tool: Data Map - What Personal Information Do You Hold?
Resource: Sensitive Personal Information.
Event: Deputy Commissioner: Angie Farquharson
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Week 11: Apr 22, 2024
Activity: Review appropriate conditions for using personal information
Tool: Conditions for using personal information: Scenarios
Resource: Conditions For Using Personal Information
Event: Questions for Commissioner White submissions - closed
Week 12: Apr 29, 2024
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Activity: Finalise, collect & store inventory & mapping records in a secure place.
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Tool: Review Q2 Checklist
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Resource: Revisit inventory resources Weeks 7-11
Week 13: May 6, 2024
Activity: Raise awareness by discussing the risks & harms of misuse of personal information at a general staff meeting
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Tool: Privacy Risk Threshold
Resource: What's the harm if personal information is misused?
Event: Privacy Pro Information Session
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Week 14: May 13, 2024
Activity: Ask members of the Privacy Committee to identify potential risk of unauthorised use or access to personal information
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Tool: Privacy Impact Questionnaire
Resource: How The Privacy Pro does PIAs
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Event: 'Road to PIPA' Survey
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Week 15: May 20, 2024
Activity: Identify controls to mitigate risk and ensure the business purpose can still be accomplished.
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Tool: Security Safeguards
Resource: The 8 themes of IASME Cyber Baseline
Event: PIPA Compliance facilitated by Duncan Card of Appleby Global
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Week 16: June 3, 2024
Activity: Work with Privacy Committee to set a realistic timeline for implementing controls needed to mitigate risk
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Tool: Privacy Impact Assessment findings and Mitigation Plan
Resource: Mid-Atlantic Privacy: Our Community Needs a Data Protection Social Contract
Event: Privacy Impact Assessments: Dr Marissa Stones
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Week 17: June 17, 2024
Activity: Identify common scenarios where security might be breached & use the PIA to assess how this might affect both the individuals and the business
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Tool: What happens if there is a breach?
Resource: Revisit Risk Assessment resources - Weeks 13 - 16
Event: Policy Writing & Record Keeping for PIPA - hosted by Data Protection People.
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Week 18: June 24, 2024
Activity: Work with Privacy Committee members to create procedures for their units/processes using information from the data life cycle
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Tool: HR Privacy Policy & Procedure Checklist
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Resource: Maintaining privacy in email communication
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Week 19: July 1, 2024
Activity: Document internal procedures for staff
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Tool: Internal Privacy Procedures Template
Resource: Q3 Checklist
Event: Policies and Procedures with Nancy Volesky (youtube.com)
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Week 20: July 8, 2024
Activity: Create a retention & destruction schedule:
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How long does each unit need to retain PI?
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Are there legal requirements besides PIPA
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Tool: Data Retention & Destruction Schedule Template
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Resource: PIPA, Bermuda’s privacy law
Event: KPMG Webinar 2: Deep Dive: PIPA vs GDPR – 15 July
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Week 21: July 15, 2024
Activity: Hold a Staff Training Event
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Tool: Revisit Policies & Procedures Tools Wks: 18-20
Resource: GPEN Press Release
Event: Navigating PIPA Compliance: Royal Hamilton Amateur Dinghy Club
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Week 22: Aug 12, 2024
Activity: Develop role-based training for individual staff that use personal information in the workplace. Make sure that training is:
* Targeted
* Practical
* Actionable
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Tool: Training vs Awareness
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Resource: Guidance: Privacy in the Workplace
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Event: Lightning Talk - Duncan Card: Partner - Appleby (Bermuda) Ltd
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Week 23: Aug 19, 2024
Activity: Conduct Role-Based Training. Remember, it needs to be:
*Targeted
*Practical
*Actionable
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Tool: Employee Scenario
Resource: Protecting Personal Information in the Medical Field
Event: Road to PIPA: Weeks 1-21 Overview
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Week 24: Sept 2, 2024
Activity: Staff may be able to describe aspects of their work that the Privacy Committee are unaware of. Adapt procedures as needed!
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Tool: Staff training feedback questionnaire
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Resource:
Event: KPMG Webinar 3: Deep Dive: Data Mapping & RoPA :Road to PIPA webinar 3: Deep Dive: Data Mapping & RoPA​​​​​