Why your company needs a chief privacy officer

The CPO is distinct from, but complements, the CISO

In this era of data breaches and identity theft, chief privacy officers working hand-in-hand with security groups play a crucial if little-known role in protecting identifiable personal information.

The position of privacy executive is a relatively new one, dating back less than ten years, says Chris Zoladz, vice president of information protection and privacy with Marriott International. He pegs this role at about the stage where the security profession was 10 to 15 years ago. Although many organizations might believe the privacy function is covered by security groups, Zoladz told security professionals at The International Information Systems Security Certification Consortium’s (ISC2) 2007 SecureAmericas conference, held near Washington, D.C. last week, why the privacy function is separate but complementary.

“There are a lot of similarities between the professions, [such as] the focus on business value,” he told the audience. The CPO is more focused on what data in an organization needs to be protected, however, while the security department develops and manages the way to protect it. “The CPO defines the ‘what,’ the CISO deals with the ‘how,’” he said.

Zoladz, who was first a security professional and received his Certified Information Systems Security Professional (CISSP) certification years ago, said the recent legislation that forces companies to disclose when a customer’s or employee’s information could be the target of identity theft — despite the trauma that such companies as TJX are suffering through with their own breaches — is a good thing.

“Good privacy is good business. The stakes in this area are constantly getting higher and higher . . . now we’re reading about [data breaches] in major media outlets,” he said. “That’s done a lot for consumer awareness . . . and has raised the consciousness and awareness of our managers. That’s a positive move forward.”

Recent regulations, be they government- or industry-driven, also have heightened the need for companies covered by them to employ a CPO, he said.

Zoladz defined privacy professionals as custodians — not owners — of personal information and said they must ensure that data is used in a responsible manner. Offering an example of his company’s Web site, he said because Marriott collects personal information from guests as part of the hotel chain’s reservation process, marketing executives have proposed personalizing the information that appears on the site so it’s customized to each visitor’s preferences. He said he gets involved in these proposals to make sure guests’ information is used properly.

“Privacy [professionals] get deeply involved in how information gets repurposed and reused, to make sure it’s done in a way that’s good for customers and for business,” Zoladz said.

CPOs typically spend their time responding to incidents, developing policies and advising the organization, Zoladz said. There's a strong legal aspect to the profession — which is why 30% of CPOs are attorneys, he said — and 15% are in the information security department. Healthcare and financial services are the two industries with the highest concentration of CPOs, probably because these industries are so highly regulated.

There’s something else CPOs and CISOs have in common: Their career paths usually aren’t well defined, he said — “Which means there’s a lot of opportunity.”

Zoladz is also treasurer of the International Association of Privacy Professionals (IAPP), which has launched the IAPP certification, a three-hour test that is to the privacy profession what the CISSP is to the security profession, he said.

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