The DHS Data Privacy and Integrity Advisory Committee of the Privacy Office of DHS has sent a letter to the new Secretary of Homeland Security, Janet Napolitano, making some recommendations for the adjustment of the way the department deals with privacy policy and issues. Some of the more notable ones include:
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Compartment Privacy Officers
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Data Governance
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Interoperability and Data Integrity
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Overhaul of the 1974 Privacy Act
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Independence of the Privacy Office from the rest of the organization
These are excellent suggestions, especially when applying them as a whole: having a compartment Privacy Officer, that can act independently of the rest of the organization has the potential of channeling the efforts of the department into the right direction. Improved data governance, integrity, and better interoperability should really be on the agenda of the CIO as well, but especially in the context of E-Verify or Border control these issues also gain a privacy facet.
Overall, this letter should be a recommendation not only to the DHS, but government and private organizations in general (mutates mutandis). Major privacy invasions (as we have recently witnessed them en force in Germany) can only be avoided if privacy compliance is considered as critical to an organizations success as any other good governance principle.