When should a breach be considered discovered?

A breach should be considered discovered when any workforce member becomes aware of it. This understanding aligns with the principle that breaches can occur in various ways and that awareness by any individual within the organization triggers the obligation to investigate and respond to the situation, regardless of their position or role.

This approach ensures that the organization is proactive in addressing potential risks and can take appropriate corrective actions before the situation escalates further. Timely response is crucial in minimizing potential harm to individuals affected by the breach and in maintaining compliance with regulations governing privacy and security.

The requirement for awareness emphasizes the collective responsibility among all workforce members to monitor and report any privacy concerns, rather than placing the onus solely on a specific role, such as a Privacy Officer or the individual who committed the breach. This fosters a culture of compliance and vigilance throughout the organization.