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When devising effective employee policies to address a particular issue, it is important to include the rationale for the policy in the first draft, as it explains why the policy is needed and what benefits it brings to the organization and its employees. The rationale can also help to gain support and buy-in from the management and staff, as well as to align the policy with the organizational values and goals. The other options are also important elements of an employee policy, but they can be added or refined in later drafts. References: CIPM Body of Knowledge, Domain IV: Privacy Program Communication Activities, Task 2: Develop internal communication plans.

The important principle of Data Lifecycle Management (DLM) that will most likely be compromised if Anton executes his plan to limit data access to himself and Kenneth is ensuring data retrievability. Data retrievability refers to the ability to access and use data when needed for business purposes or legal obligations1 It involves maintaining the availability, integrity, and usability of data throughout its lifecycle2 However, if Anton restricts data access to only himself and Kenneth, he will create a single point of failure and a bottleneck for data retrieval. This could pose several risks and challenges for the company, such as:

Losing data if Anton or Kenneth forgets the password or leaves the company without sharing it with others.

Delaying data retrieval if Anton or Kenneth is unavailable or unresponsive when someone else needs the data urgently.

Violating data protection laws or regulations that require data access by certain parties or authorities under certain circumstances.

Reducing data quality or accuracy if Anton or Kenneth fails to update or maintain the data properly.

Missing business opportunities or insights if Anton or Kenneth does not share the data with other relevant stakeholders or departments.

Therefore, Anton should reconsider his plan and adopt a more balanced and secure approach to data access management that follows the principle of least privilege. This means granting data access only to those who need it for their specific roles and responsibilities and revoking it when no longer needed3 He should also implement proper authentication, authorization, encryption, backup, and audit mechanisms to protect the data from unauthorized or unlawful access, use, disclosure, alteration, or destruction4 References: 1: Data Retrievability: What Is It?; 2: Data Lifecycle Management | IBM; 3: What is Least Privilege? Definition & Examples; 4: Technical Security Controls: Encryption, Firewalls & More

“Respond” in the privacy operational lifecycle includes information requests and privacy rights requests, which are requests from individuals or authorities to access, correct, delete, or restrict the processing of personal data. The privacy program must have processes and procedures to handle such requests in a timely and compliant manner. The other options are not part of the “respond” phase, but rather belong to other phases such as “protect”, “aware”, or “align”. References: CIPM Body of Knowledge, Domain III: Privacy Program Operational Life Cycle, Section D: Respond.

Developing the right privacy framework for your organization means that you have a clear and coherent set of policies, procedures, and practices that align with your privacy objectives and obligations. A good privacy framework should improve the consistency of the privacy program by ensuring that all relevant stakeholders understand and follow the same standards and expectations across different functions, processes, and systems. A consistent privacy program can also help reduce errors, risks, and costs associated with privacy compliance.