We’ve all been there. Sitting around the conference room with our compliance teams, droning on about scheduling conflicts, procedural details and strategy about strategy. Here are some actual substantive ideas, initiatives and approaches to privacy, data governance and cyber-security that can get the ball rolling next year.
1. Policies aren’t just documents you keep around in case you might have to show them to a judge one day. Start putting them to work and leveraging their authority to cut costs and reduce operational risks!
For example:
- Privacy policies, now required to be updated annually by the State of California, can actually help drive data mapping exercises, leading to new insights into structured and unstructured data systems. Use those insights to help patch gaps in your IT infrastructure and even retire costly, redundant systems, classify shadow IT and discard unused shelfware.
- Retention policies can be used as virtual blueprints to justify and destroy, costly, over-retained paper records and electronic data lingering around the office and waiting to be discovered… by your adversaries!
- Cyber-security policies like those required by the New York DFS can be used to help IT decision makers prioritize strategic investments in your cyber-defense software.
2. Chief executives realize audits are necessary to continually optimize business processes, but even the sharpest leaders sometimes forget the most sobering, useful assessments are conducted by outside parties who don’t have an inherently biased interest in determining the findings.
Executives need to make sure they are told what they need to hear, not what they want to hear.
3. One of the reasons assurance departments like compliance, risk and internal audit struggle with their annual reviews is because of a lack of policy organization within their OWN departments.
Lack of procedural consistency, ownership of policy and overlap and confusion over a directives authority in can create even more conflict, risk and uncertainty for an organization. But relying on institutional knowledge and spreadsheets just doesn’t cut it anymore. That’s why every regulated company needs a strong technology backbone in the form of a GRC or governance risk and compliance software.
4. These days the risk is not just internal. With so much of our data in the cloud and managed by other parties, some of the greatest risks have moved outside of the firewall.
Organizations need strategies and tools to help them prioritize and manage those vendor risks effectively. Sophisticated and affordable tools that address consumer data privacy requests can also be used to map and streamline an organizations external data, whether it’s private in nature or otherwise.
5. Finally, risk is not a one size fits all problem. Investment needs to be proportional to the exposure. That’s why it’s important to spend enough time planning your long-term strategy rather diving headfirst into solutions that promise the moon and end up creating more infrastructure dependency than you bargained for.
Rafael Moscatel is Managing Director of Compliance and Privacy Partners, a consulting firm specializing in data governance and privacy solutions. He is an award-winning Information Governance Professional (IGP), Certified Records Manager (CRM), Certified Information Privacy Manager (CIPM). Rafael has spent the last twenty years developing large-scale Information Management Programs for the Fortune 500 including Paramount Pictures and Farmers Insurance. Reach him at 323-413-7432, follow him on Twitter at @rafael_moscatel or visit http://www.capp-llc.com to learn more.
