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Some Lessons Learned
Successful privacy programs create cross-functional privacy councils.
Such councils enhance communications and secure senior management buy-in.
Privacy officers should have the authority to request a PIA, regardless of the stage in a system's development lifecycle.
Be viewed as a facilitator to the OMB 300 process.
Create customized employee training modules.
Annual privacy certification for functions like HR, information technology, and government auditors.
Vendors must consider the specific needs of the government market.
Need for alternatives to data aggregation.
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