Cooperation between the CIO and the CPO is a recipe for a successful privacy initiative, says Michelle Dennedy, chief privacy officer at Sun Microsystems. Lack of cooperation is a recipe for... well, you know."A lot of CPOs are struggling with -- what is privacy? How does this work?" says Dennedy, who became Sun's chief privacy officer four years ago. Dennedy divides her work into four quadrants: (1) compliance with the company's privacy policy as it relates to employees; (2) privacy compliance as it relates to customers; (3) compliance as it relates to Sun's products and services; and (4) "Talking with people around the world about privacy issues."

Dennedy's Chief Privacy Office is a four-person operation (including herself), but Sun also has a company-wide Privacy Council made up of about 80 business unit representatives. "Anyone who owns a stake in information [at Sun] owns a stake in the Privacy Council," she says.

Dennedy works most closely with Sun's CIO, Bob Worrell, and the company's chief information security officer, Leslie Lambert. Those three, along with the company's chief compliance officer ("who owns our business conduct rules") and an internal audit executive make up what Dennedy refers to as "an ad hoc governance group," in particular in relation to the application of IT systems within Sun.

Keeping track of those systems, and the information they represent concerning both employees and customers, is the most daunting part of her job. "My challenge is to look at the data going through the pipes," she says.

That's why cooperation between herself and the CISO, and their relationship with the CIO, are critical to making the privacy effort real. "Relationships in this area are just key," she says. "Especially if you have a small team and don't have a key to turn off the machines that are doing the damage, You need to have access to the person who does," Dennedy says.

Dennedy authored a whitepaper on the subject called "The CIO And The CPO -- A Vision For Teamwork And Success," which you can find here.