Privacy on the Ground: Driving Corporate Behavior in the United States and Europe by Kenneth A. Bamberger & Deirdre K. Mulligan

Author:Kenneth A. Bamberger & Deirdre K. Mulligan [Bamberger, Kenneth A. & Mulligan, Deirdre K.]
Language: eng
Format: epub
Tags: law, Privacy, Business & Economics, General
ISBN: 9780262029988
Google: 8NTaCgAAQBAJ
Publisher: MIT Press
Published: 2015-10-23T00:26:24.638551+00:00

Maturation of the CIL Position

A number of interviewees suggested that the maturation of the position of the CIL is an important, albeit recent, development. To be sure, the CIL position has officially been on the books for a number of years. Yet the comments of some privacy leads, especially those who recently assumed a formal privacy lead position, suggest that the availability of the CIL designation has more recently helped generate a more influential privacy professional presence, and a more robust internal privacy practice. Those designated as CILs earlier in the position’s life cycle spoke less about the position’s capacity for heightening influence and independence within the firm. But the accounts of several more recent CILs suggest a strengthening CIL role in France. Sounding very much like a counterpart in Germany might, one recently designated CIL described confidently, “I’m independent, by the law. The French law says that when a CIL is appointed, he is independent. That means, that it’s written in the law, that no one should tell me what to do, nor how to do it.” Key to that independence, in that privacy lead’s view, was access to the corporate board. “[R]eporting to the CEO is in the law” as is the duty to alert:

If there’s a functional problem in the company, for example, data that was accessed by people who shouldn’t have, and I’m aware of it, and my colleagues did not do as they were supposed to, I must alert. So I have a procedure that I put in place, where I [send] the alert. First to the director who should know in the enterprise, pretty high up in the enterprise, to tell them, here is the problem, here is the law. What will you do to correct this? When will you correct this?” [And] when I do an alert, I do two or three per year; it’s corrected in the month that follows.

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