I bet the legal team will have a field day reviewing all the privacy policies. They'll probably find enough loopholes to keep themselves busy for years!
The internal audit department establishing audit controls to test for policy effectiveness is a great idea. They can provide an independent assessment of how well the policies are being implemented.
As a member of the Senior Management Team, the CIO should be responsible for creating enterprise-wide privacy policies. That way, the controls can be consistently applied across the organization.
The legal department or outside counsel should definitely conduct a thorough review of the privacy program and policies. They can ensure we're compliant with all relevant laws and regulations.
I think the IT group is the best choice to support and enhance the privacy program. They have the technical expertise to develop the necessary processes and controls.
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