You are a compliance professional working for an executive at a mid-sized financial institution. The executive is organizing a tabletop exercise as part of the company’s data breach response planning efforts. In the hypothetical scenario to be used for the tabletop, the company will be responding to a breach of consumer financial account information, including account numbers and social security numbers, that appears to be the result of an inadequate security program.
While getting ready to conduct the tabletop exercise, the executive has realized that the company’s Chief Security Officer (CSO) and Chief Privacy Officer (CPO) are not talking to each other and have been working independently in a siloed manner. In fact, their relationship is quite hostile and contentious. The CSO thinks that the CPO is trying to do work activities that are within his area of responsibility. The CPO is upset that the CSO does not include her or listen to her recommendations in the development of technology solutions.
Please prepare advice for the executive about whether either or both the CSO and CPO should participate in the data breach response tabletop exercise. Also advise the executive about whether he should take steps to help the CSO and CPO work collaboratively in the future or if it is fine for them to work separately without engaging each other and explain why you are offering that advice. Share with him some suggestions on what could be contributing to the views of the CSO and CPO about each other based on what you know about the roles and responsibilities of privacy and security professionals. In your advice to the executive, be sure to include relevant legal and policy concepts related to privacy, security, compliance, and data breach response. Note for the executive any risks that he may be facing.