PRV: Privacy Program
Document Type
Code: PRV
Name: Privacy Program
Domain: Risk & Governance
Abstract
This specification defines the Privacy Program document type within the BSpec 1.0 Universal Business Specification Standard. It separates privacy governance from security controls and security compliance workflows.
Purpose and Scope
Privacy Program defines lawful data processing practices, privacy rights management, and regulator-facing controls for privacy obligations. It complements security (SEC-*) by focusing on rights, consent, and purpose discipline.
Document Metadata Schema
yaml
---
id: PRV-{privacy-program}
title: "Privacy Program — [Program Name]"
type: PRV
status: Draft|Review|Approved|Active|Deprecated
attribution_required: false
version: 1.0.0
owner: Compliance-Lead|Privacy-Officer|Legal-Lead
stakeholders: [privacy-officer, legal, security, product, engineering]
domain: risk-governance
priority: High|Medium|Low
scope: privacy
horizon: strategic
visibility: internal
depends_on: [SEC-*,REG-*,COM-*,DAT-*]
enables: [COM-*,LEG-*,SEC-*,GOV-*]
lawful_basis_framework: [consent, contract, legal-obligation, vital-interests, legitimate-interests]
data_subject_rights: [access, correction, erasure, portability, objection]
consent_model: opt-in|opt-out|contractual
cross_border_controls: [transfer-impact-assessment, SCCs, equivalent-protections]
review_cycle: quarterly
---Program Structure
- Data Mapping: Data classes, controllers, processors, and transfer paths.
- Purpose Limitation: Lawful purposes and data minimization standards.
- Consent Management: Collection, records, withdrawal, and evidence retention.
- Rights Handling: Intake-to-closure process for access/deletion/portability and complaint workflows.
- Incident Interface: Privacy breach escalation to
INC-*and legal stakeholders.
Jurisdictional Context
- Distinguish GDPR, CCPA/CPRA, and regional regimes (for example, Quebec Law 25, Alberta PIPA, BC PIPA) where they apply.
- Avoid assuming direct equivalence across privacy regimes.
Validation Checklist
- [ ] Data processing purposes are explicitly defined and traceable.
- [ ] Legal basis is documented for each sensitive data stream.
- [ ] Privacy rights workflows are testable and measurable.
- [ ] Transfer and third-party controls are explicitly governed.
- [ ] Incident and breach pathways are connected to governance routines.