Privacy on Products & Service Development
Concept Phase
All involved units, together with Data Protection Officer (DPO), collaborate to ensure that the concept is aligned with BCA’s internal personal data protection policies, personal data protection principles, and relevant Personal Data Protection (PDP) Laws.
Planning Phase
BCA implements privacy safeguards including, but not limited to:
Creation and verification of Records of Processing Activities (ROPA)
Risk assessment covering PDP-related risks
Due diligence on third parties involved to mitigate risks related personal data processing
Consent review when using consent as the legal basis
Legitimate Interest Assessment (LIA) when using legitimate interest as the legal basis
Personal data protection measures such as encryption, anonymization, pseudonymization, and data masking
Testing Phase
Technical consultation are carried out to verify that PDP principles and protection measures established in the planning phase have been implemented. Additional checks are also conducted to identify any personal data processing and/or its risks.
Monitoring Phase
Following deployment, compliance with PDP policies and data protection principles is continuously monitored. BCA is also committed to fostering a privacy-first culture across our bank, ensuring that privacy considerations are ingrained in the mindset of all units, including BCA’s development teams.
Privacy Risk Assessment Phase
Furthermore, BCA ensures that risk assessments are conducted on existing products and services prior to the introduction of new ones. This assessment evaluates the potential privacy risks associated with current offerings, identifies gaps in personal data protection measures, and ensures that any necessary remediation is carried out before new products or services are launched. By doing so, BCA ensures that the introduction of new offerings does not compromise the privacy standards already established in existing products and services. This approach reflects BCA’s commitment to integrating privacy by design throughout BCA’s product and service development process.