C. Create an inventory of systems where personal data is stored.
When establishing a new data protection program that must comply with applicable data privacy regulations, the first step should be to create an inventory of systems where personal data is stored. This step is crucial for understanding the scope of personal data processing within the organization, which is foundational to developing effective data protection policies and procedures. Options A, B, and D are important considerations in building a comprehensive data protection program, but creating an inventory of systems is the initial step to gain visibility into where personal data resides within the organization.
C. Create an inventory of systems where personal data is stored.
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