Virtual Data Protection Officer (vDPO)

vDPOs are data privacy leaders who oversee data protection strategies and program implementation to support compliance with privacy regulations and alignment with business strategy. If your organization collects personal data, you must likely comply with one or more data privacy laws. From GDPR to CCPA and everything in between, there are significant fines and business impacts if you fail to operationalize a functional privacy program.

This service will focus on advising management on privacy compliance issues, creating a privacy program, and serving as the Client's Data Protection Officer (DPO). 

The objectives of this initiative are as follows:

1. Clearly communicate and effectively integrate all data protection obligations into the strategy and operations
2. Act as the primary interface between your organization and supervisory authorities
3. Monitor data privacy program compliance to validate alignment with ever-changing laws, advise on impact and support smooth audits
4. Review and recommendations on privacy-related policies and procedures
5. Long-term privacy program management, staffing, and sustainability
6. The ability to maintain "independence," and compliance, as defined by:
   1. Europe's General Data Protection Requirements (GDPR)
   2. California's Consumer Privacy Act (CCPA)

The methodology consists of the following activities:

1. INITIALIZATION MEETING - DeepSeas will host an initialization meeting to review the objectives, methodology, scope, and deliverables in the Statement of Work.
2. PLANNING - Preparation necessary to conduct an effective engagement, including:
   1. Scope Validation - Validating the scope to align all parties
   2. Schedule Development - Scheduling, project plan creation, and resource identification
3. PROGRAM DESIGN - Design a sustainable privacy program to monitor compliance and remediate deficiencies for applicable regulations, including:
   1. Design a sustainable 12 - month privacy program
   2. Analysis of remediation activities at the category level based on risk
   3. Document leverageable processes and technologies
   4. Data Protection Officer requirements
4. PROGRAM EXECUTION - Documentation of all deliverables, including:
   1. Remediation Execution - Manage and execute the needed remediation to bring the client in compliance with the base regulation
   2. Programmatic Execution
      1. Execute programmatic items to keep the client in compliance with the base regulation
      2.  Conduct assessments against other relevant regulations
      3. Annual assessment against the base regulation

The following are possible deliverables, as part of this service:

1. Possible Deliverables
   1. Regulatory Relevance Analysis
   2. Privacy program documentation
   3. Ongoing strategic privacy recommendations
   4. Data subject request/response reports
   5. Revised data protection and privacy policies, procedures, and plans for management's approval
   6. Privacy educational plan and reporting
   7. Compliance metrics reporting
   8. Supervisory authority activity reporting
   9. Data privacy briefing materials, staffing, and resource plan
   10. Metrics report
   11. Annual assessment report
   12. Remediation recommendations

The service described in this Statement of Work will be delivered by DeepSeas according to the following assumptions, which will govern all work, deliverables, and interactions:

1. Services will be conducted remotely unless otherwise agreed upon.
2. Scheduling will be initialized once the signed proposal has been received.
3. The Client will provide adequate support, preparedness, and cooperation from management.
4. If a privacy management platform is deployed, the Client will be responsible for all platform licensing and/or hosting costs.
5. All interviews, data provided, questionnaires, surveys, and deliverables will be in English.
6. The Client will be provided one draft and one version of any written report.
7. A change control process will be utilized to evaluate any additional work changes or exceptions that are not otherwise detailed in this statement of work.

The Client is responsible for the completion of the following tasks, in accordance with agreed-upon timelines established as part of the project plan.

1. The Client will appoint a representative to oversee the privacy program and DeepSeas services under this Statement of Work. The Client agrees that their representative shall be authorized to direct DeepSeas work and make decisions on behalf of the Client.
2. Client will be responsible for ensuring the appropriate individuals are available for meetings and inquiries required throughout the project.
3. The Client will be responsible for providing requested feedback and review in a timely manner.
4. The Client is responsible for implementing recommendations.