Category: Privacy

Business Processes Data Governance Privacy Records Retention Policy

7 Ways To Prepare Data In The Age Of Privacy and Information Governance

By Rafael Moscatel, CRM, IGP

7 Ways To Prepare Data In The Age Of Privacy and Information Governance

7 Tips for Data Preparation in the Age of Information Governance

Content may still be king, but now the rights to some of it may belong to the people! In response to the EU’s General Data Protection Requirement (GDPR) and recent stateside efforts to enshrine data protection including the California Consumer Privacy Act (CCPA), organizations are revisiting the efficacy of their Data and Information Governance (IG) programs. Laws and regulations vary by industry and company size but each intend to protect consumer’s personal data by prescribing technical and governance standards backed by stiff penalties for non-compliance.

Notably, while many companies are already familiar with records retention laws, these latest controls also introduce a duty to destroy data once no longer required for a legitimate business purpose. For entities that have grown accustomed to leveraging cheap digital storage, this new responsibility presents a number of logistical hurdles.

However, directives on how you may use your customer’s data or any other information you store doesn’t necessarily have to be burdensome. In fact, these new guardrails present numerous opportunities to implement better governance, monetize the lifecycle of information assets and foster trustworthy relationships that can actually enhance the customer experience.

These 7 tips can help prepare your data to support an IG strategy:

  1. Automate Retention Schedules – Legal and compliance requirements are the cornerstones of corporate governance programs. Yet tracking the multitude of historical and emerging state, federal and international laws and regulations that affect your data decisions can be a monumental task that even the most robust law departments aren’t prepared for. Consider leveraging SaaS software to keep your Risk, Compliance and Legal staff current on the latest citation changes to these nuanced instructions. These tools empower you to defensibly destroy and cleanse costly data no longer useful to your organization.
  2. Cover Your Assets – Satisfying new compliance requirements like GDPR and CCPA means it’s not enough to simply know what kinds of records you keep, you need to know what systems they’re kept in and how that data flows between them. That’s why Chief Data Officers and Enterprise Architects are increasingly embracing asset management tools that not only perform diagnostics on their application stack but allow them to inventory their attributes and map related processes that inform long-term strategic roadmap planning. Tools like these also help support application rationalization projects which in turn aid in classification and disposal of unneeded data.
  3. Introduce Big Buckets – The biggest challenges with enforcing retention across an enterprise are “event triggers” that complicate how long sets of records must be retained. For example, an employee file might be held X years following a termination “event.” Big Bucket strategies allow you to simplify and group “like” records together to support more efficient destruction actions while assuming some risk. Work with your governance partners to determine reasonable standards for a Big Bucket policy and quantifying the acceptable amount of risk your company is willing to assume to achieve cost and efficiency benefits.
  4. Enforce Legal Holds – Cleansing your data lakes and silos to save costs and minimize risk is an exercise in defensible destruction but requires awareness of outstanding legal holds. A company that spoliates evidence subject to a legal hold, even without malice, can be fined and suffer adverse inference litigation rulings resulting in unfavorable judgments. Additionally, healthy oversight of records under a preservation hold doesn’t just make good legal sense, it can also help better identify opportunities for even more defensible destruction, cost reduction and risk mitigation.
  5. Activate File Analysis – The tricky thing about new laws like the CCPA is that they require companies to find and produce data for the consumer wherever it exists. That can be a cumbersome test for many entities that have hundreds or thousands of repositories. Luckily, advanced File Analysis tools can plug directly into your network and help quickly identify sensitive and personally identifiable information (PII). They can also help you deduplicate records and find redundant, obsolete and trivial data clogging your systems, also known as ROT. These tools produce a tangible ROI that management can point to as a prime example of why IG works.
  6. Embrace Content Migrations – Unless you’ve only lived in one home your entire life, you’ve probably experienced the cathartic process of cleansing your old wares in preparation for a move. Bringing in a new content management system is not much different and it’s a unique opportunity to apply retention to your data, discard ROT and provide employees with more accurate knowledge resources.
  7. Bake-in Best Practices – Information Governance is not a “one and done” proposition, it’s a rinse and repeat discipline that only works when management sees to it that organizational culture is along for the ride. These days a basic understanding about data handling is vital for every new hire. Concepts like records retention, data protection and privacy should be part of any overall corporate training plan.

By complementing policy frameworks and toolsets with the types of Information Governance approaches noted here we can better enable our workforce to hone their knowledge skills, achieve defensible destruction and improve audit outcomes. In effect, we are future proofing ourselves for a business world destined to face increased scrutiny and under siege from data breaches and privacy issues with seemingly no end in sight. IG is the bright light at the end of that tunnel.

Rafael Moscatel, CRM, IGP, is the Managing Director of Compliance and Privacy Partners, LLC. Reach him at 323-413-7432, follow him on Twitter at @rafael_moscatel or visit http://www.capp-llc.com to learn more.

Originally published in Document Media Magazine, July 2019.

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UPCOMING PRIVACY WORKSHOP IN LA 7/31: Leveraging a GDPR Compliance Investment for CCPA / Privacy By Design

By Rafael Moscatel, CRM, IGP

UPDATE: Presentation Slides Included Below

 

ARMA-GLA Summer Spotlight Workshop

LEVERAGING A GDPR COMPLIANCE INVESTMENT FOR CCPA / PRIVACY BY DESIGN WORKSHOP

Part I – Join European attorneys and privacy compliance experts from Brussels based law firm Ethikos to learn how to leverage GDPR compliance investments for California’s new Consumer Privacy Act. In this presentation they’ll review key data protection concepts and privacy by design strategies already in place across the EU and explain how they’re now spreading throughout the United States. Find out what you need to know about the rules of transferring data and records internationally, PII records retention requirements, rules for managing content on customer facing websites and the impact of these new records management guidelines in contract negotiations.

SELECT THE LINK BELOW TO VIEW THE WHOLE  PRESENTATION.

ETH-CAPP-2019-LA-PbD

Part II – Meet solutions engineers from Active Navigation who will show you real world examples of how state of the art privacy software helps apply concepts and rules from GDPR and CCPA directly into an information lifecycle program. Learn about machine learning classification, consent validation, uncovering dark data and many more intricacies of implementing a privacy framework as part of your Information Governance roadmap.

Presenters

Miguel Mairlot, Ethikos Law Firm, Brussels

Miguel Mairlot is a trusted compliance expert, with significant breadth of experience across Europe. He provides clients with advice and support on all aspects of their compliance program. His areas of expertise include Asset Management, Wealth and Insurance businesses to cover cross-border regulatory issues, risk management, contractual documentation and product development, advising and influencing senior stakeholders at executive committee level, enabling them to meet their responsibilities across a range of group policies and local requirements, including MiFID II, GDPR, AML, ABC and Sanctions. Before Ethikos, Miguel has worked for prestigious international law firms and financial institutions as Head of Compliance. Miguel speaks English, French, Dutch and is a Certified Compliance Officer (Febelfin Academy) since 2013 and a Data Protection Officer. He has written and spoken widely on compliance and financial law topics and teaches at the Cooremans Institute. He also serves on the Editorial Board of “la Revue de Droit Bancaire et Financier”.

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20 Years After Google: In Search of a Better Way to Search

By Rafael Moscatel, CRM, IGP on

From its inception the internet has always been about search…. searching for that answer, that perfect example, that one you love? But search has also changed the way we think about information, about primary sources and really about each other in wildly different ways that aren’t always, well….helpful.

In the wrong data steward’s hands the integrity of our records and information, both in the style and context in which it is delivered, can be easily and unfairly distorted. This has worsened over time and is horrifying when you consider the extent of “deep fakes,” “fake news” and other purposeful misleading propaganda being spread. A trend towards misinformation and bias is clearly what has happened over time with Google’s search results and it’s having disastrous unintended consequences on the pursuit and preservation of knowledge, wisdom and the humanities around the entire world.

With exciting new A.I. tools like Alexa and Siri becoming commonplace, search has entered a second renaissance and results have even more power to shape hearts and minds. Yet nobody, no one monopoly, should be in the business of brokering access to facts or opinions.

We need new tools that deliver intelligent results that protect the privacy of its users and promote resources which enrich our lives, communities and world around us without exploiting our vulnerabilities.

With proper regulation of monopolies like Google there’s going to be a better way to find what you “need” without being subtly persuaded how to believe and incessantly pestered about what you should “want” along the way. In other words, a return to search that offers a wealth of information minus manipulation.

True search results should provide access to knowledge you can rely on for personal, professional and academic growth. A search engine should steer you away from groupthink and encourage critical thinking, not bully you into becoming a “follower.” We need independent thinkers to reclaim their independence as information consumers, as teachers and students, as citizens, as moms, dads, brothers, sisters and yes, even as politicians. After all, the internet has the power to be the great equalizer in spreading knowledge. But that knowledge can only bring light to our present darkness if it can shine through the praetorian ideologues that have begun to guard its boundless prism.

Google was perfect for its time and helped both connect and open the world to itself. Yet now, as our collective tastes become more refined, we realize our search time is equally as valuable as increasingly for-profit algorithms. Rather than wasting another moment sifting through information curated through a corporate or political filter, knowledge seekers should demand to be able to create their own!

We deserve new tools that deliver intelligent results that protect the privacy of its users and promote resources which enrich our lives, communities and world around us without exploiting our vulnerabilities.

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Establishing a Framework to Sustain the Coming IoT Tsunami – An Interview with Priya Keshav of Meru Data

By Rafael Moscatel, CRM, IGP on

Establishing a Framework to Sustain the Coming IoT Tsunami – An Interview with Priya Keshav of Meru Data

Ninth in a series of in-depth interviews with innovators and leaders in the fields of Risk, Compliance and Information Governance across the globe.

Priya Keshav is the founder and CEO of Meru Data LLC, a software company focused on building solutions that simplify and achieve corporate information governance goals. Prior to Meru, she was the leader of KPMG’s Forensic Technology Services Practice in the Southwest United States. She received her MBA from University of Florida’s Warrington College of Business Administration. I had the chance to sit down with her this January and discuss IG, the Internet of Things, consulting, and software development.

Priya, you’ve written extensively, often in collaboration with thought leaders in IG including Jason Baron, about the enormous ethical questions emerging from IoT. Do you think there is yet a universal, cross-industry awareness of these challenges or are business drivers in this area primarily the result of European or US regulatory pressures?

I think there is universal recognition that the use of IoT will bring unique challenges and ethical questions. However, I would not call this universal awareness or understanding at this point. The use of IoT is rapidly increasing, the solutions being developed are integrating multiple industries and we are just scratching the surface of what is possible with IoT. I think today, we are at a point where we recognize that some unique challenges are going to arise. I do not believe we have fully understood the nature of these challenges, especially as the uses and applications for IoT are rapidly evolving.

Both industry and regulators are at the same point – thinking about appropriate frameworks for discussing and addressing these challenges. I don’t believe regulatory pressures from either Europe or the US are the primary drivers for the growing awareness. It does seem regulators have more of a focus on the challenges while the industry focus is more around creating newer solutions. There are multiple efforts underway to understand challenges with IoT, driven by both industry and regulatory interest. However, I do not think this is primarily due to regulatory pressure. There is regulatory interest that has industry taking notice but even the industry is realizing the need to manage the unique challenges from the use of IoT. Existing regulations like the GDPR, COPA etc. obviously would apply to IoT. There is increased scrutiny and regulations around data privacy and security in general and that might look like there is increased regulation around IoT. However, there are very few IoT specific regulations like the California SB327.

Regulatory efforts around IoT to date have been more guidelines focused and have tried to not slow down the uptake of IoT. Examples include the recently issued NIST draft report on IoT cyber security standards that provides a great discussion of how risks from IoT are unique and how organizations could adapt their policies to handle this. There have also been integrated efforts with working groups to review existing IoT security standards and initiatives in the US (by the National Telecommunication and Information Administration) and in Europe (Working Group 3 formed by Alliance for Internet of Things Innovation). Other agencies like the the Consumer Products Safety Commission and the FTC have also been gathering comments on their roles in regulating IoT.

With the Meru Data platform, you’ve strived to develop a functional and reporting tool that simplifies and sustains data governance programs for your customers. Is most software today built around policy frameworks, such as FINRA compliance or privacy-by-design, and are these types of approaches even feasible amidst shifting customer wants and seemingly prescriptive laws like GDPR?

Read the entire interview and more in my new book on leadership in the information age, Tomorrow’s Jobs Today.

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Harnessing Analytical Insights and Illuminating the Physical Realm of Dark Data – An Interview with Markus Lindelow of Iron Mountain

By Rafael Moscatel, CRM, IGP on

Harnessing Analytical Insights and Illuminating the Physical Realm of Dark Data – An Interview with Markus Lindelow of Iron Mountain

Eighth in a series of in-depth interviews with innovators and leaders in the fields of Risk, Compliance and Information Governance across the globe.

Markus Lindelow leads the IG and Content Classification Practice Group at Iron Mountain, the world’s largest information management company, where he’s been pioneering breakthrough analytic techniques for over a decade. He holds a Master of Science degree in Computer Information Systems from Saint Edwards University and consults across a broad set of industries. I interviewed him in November to discuss his thoughts on the evolution of metadata, content classification, AI, and how organizations are using the new pillars of data science to break down their silos, help customers get lean and discover the hidden value in their big data sets.

Markus, you work with all kinds of companies to help them better understand and address the often incomplete metadata tied to some of their most valuable information assets in the form of historical paper records and materials retained over decades. In many cases, institutional memory has been completely lost and they’re struggling to figure out whether to dispose of these business records, balancing costs of over retention with risks of untimely destruction. How does your team leverage diagnostic, predictive and prescriptive analytics to make sense of what little data they might have to make informed decisions?

Our content classification process focuses on making the best use of the available metadata. This means classifying records with meaningful metadata as well as analyzing the classified inventory in order to create classification rules for records with little or no metadata. We have identified a number of attributes within the data that tend to correlate with classification conclusions. We assess the classified records associated with an attribute to create a profile that may inform a rule to classify the unclassified records sharing that same attribute…

If, for example, there are 100 cartons associated with pickup order XYZ, 90 of those cartons have been classified, and furthermore all 90 are classified to ABC100, can we create a rule to classify to ABC100 the 10 unclassified cartons belonging to pickup order XYZ? Clients may need to weigh the risk when applying this type of classification rule and the process may include a random sampling of cartons for physical inspection in order to verify the classification.

There’s usually a disconnect between the needs of information managers and legislatures which set retention periods for records. We see this in regulations where the granularity of both fixed and event based retention triggers complicates the practical management of records. Over the years, strategies like “big buckets” have attempted to lessen this challenge but even the best efforts are imperfect and carry their own risks. What can be done to better bridge the divide between the need for due diligence in retaining records and the business case for a more practical solution?

There are two pieces to the puzzle of records management: classification and retention. A records retention schedule needs to be straightforward enough to implement so that users can apply record codes to records. But the retention periods for the record classes need to be specific enough so that some types of records are not being over or under-retained because they are being grouped with other records…

Read the entire interview and more in my new book on leadership in the information age, Tomorrow’s Jobs Today.

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40th International Conference of Data Protection and Privacy Commissioners

By Rafael Moscatel, CRM, IGP on
40th Annual Data Protection Conference

Reflections on the 40th Annual International Conference of Data Protection and Privacy Commissioners

Guest Post by Abby Moscatel

It’s been about a week since Rafael and I returned from Europe, where we attended the 40th International Conference of Data Protection and Privacy Commissioners at the European Parliment’s Hemicycle in Brussels, Belgium.

The thought leaders posed the single most important question facing us today: What kind of world do we want to live in? You see, we are at the tipping point where the internet will know more about us than we know about each other, or even ourselves. And yet there is no recognized universal ethical and moral code for how we deal with all of the data that is being collected about us. How do we handle it? Right now, Data Kings hold the cards. Companies provide free services to gather our information.

Apple CEO Tim Cook was correct when he said that we are now in a time where our data is being weaponized. We see it in our news feeds. No matter what you believe, you get socials and content that affirms your position, and makes the opposite position something you must resist.

Tim Cook at the 40th Annual Conference of Data Protection Comissioners

Hong Kong artificial intelligence researcher Pascale Fung was also right when she said that unless we get all of the world leaders together, it won’t matter.

Now, we have the GDPR. And, here in the US, we are starting to get patchwork legislation, like the California Consumer Privacy Act, heavily resisted by Big Tech in favor of a federal privacy law.

I want to live in a world where I own my data, control access to my data, and where I can delete my information. If a company or individual breaks a law, then I want a private right of action. Most importantly, I want to live in a world where we have a universal agreement on digital ethics.

What kind of world do you want to live in?

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The Olympics of Privacy in Brussels!

By Rafael Moscatel, CRM, IGP on

Debating Ethics: Dignity and Respect in Data Driven Life, the 40th Annual Conference of Data Protection and Privacy Commissioners

Two Americans walk into a EU Privacy Conference…

Just a few weeks ago, a colleague reached out and reminded me “the Olympics of Privacy” were being held at the EU Parliament in Brussels in late October, and also if I’d like to attend. Well, how the heck am I supposed to turn down an invitation like that? After all, this is the year of GDPR, the NYDFS, the new California Privacy legislation and the ICDPPC has leaders like Mark Zuckerberg, Sundar Pichai, Tim-Berners Lee, Jagdish Singh Khehar and even the King of Spain all lining up to share their thoughts.

We want to stimulate an honest and informed discussion about what digital technology has done and is doing to do to us as individuals and as societies, and to consider future scenarios. We want to better understand the impact of technology on people of all generations, in all parts of the world, including the way people think, interact with others, develop their opinions, create art and write, how they buy and sell and how they participate in civic life.  – Privacy Conference Statement

Mark and Sundar are likely showing up because they realize the stiff penalties now associated with data security and privacy violations and the rest of the speakers realize that we are on the cusp of a digital and ethical revolution of sorts, one which will affect generations to come. In fact, Debating Ethics: Dignity and Respect in Data Driven Life is probably the most important privacy conference of the 21st century. My wife Abby Moscatel, an attorney and ethicist heard about this lineup and quickly said, yeah… I’m coming with you to this one!

Continue reading “The Olympics of Privacy in Brussels!”

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Navigating The Global Digital Economy – An Interview with April Dmytrenko, CRM, FAI

By Rafael Moscatel, CRM, IGP on

Navigating The Global Digital Economy – An Interview with April Dmytrenko, CRM, FAI

Seventh in a series of in-depth interviews with innovators and leaders in the fields of Risk, Compliance and Information Governance across the globe.

April Dmytrenko - Information Governance Perspectives

April Dmytrenko, CRM, FAI is a recognized thought leader in the field of information management, governance, compliance, and protection. As both a practitioner and consultant, she works with global organizations on key initiatives and best practice approaches for the enterprise; developing sustainable solutions; integrating legally compliant programs focused on information/digital assets; motivating and facilitating multi-disciplined groups to collaborate on achievable goals; and building strategic partnerships with internal and external teams. She serves on industry action committees and governing and editorial boards, and is an active industry speaker, trainer, and author. I had the pleasure of sitting down with April this September to discuss privacy, the role of industry associations and key concerns for leaders navigating the global digital economy.

April, almost five years ago I asked what the next big frontier would be for those of us managing data, and more importantly where the jobs would be. You wisely predicted that privacy would be on the horizon. Well we now have a number of legislatures drafting regulations and CPO positions can’t seem to be filled quickly enough. Do you believe there is still time to enter this emerging field and make an impact?

Right now we are experiencing an amazing transformation of the business environment based on many things but particularly the evolution of technology and the global digital economy. It is indeed an exciting time but we are acutely “headline news” aware of the impacts of compromised data security and privacy, including financial impact on brand and reputation, litigation, and the overall burden and distraction on the business. The exponential growth rate of incidents of data theft, damage, loss or inadvertent disclosure continues to expand not only in frequency but scope, and complexity. While privacy concerns gained attention over 100 years ago, and became topical about 15 years ago, it is still truly in an infancy state. Privacy offers IG professionals a rich and important opportunity to expand their leadership or advisory role in maturing a unified approach to protection, compliance with laws and regulations, and incident response and recovery.

April Dmytrenko - Governance - Not Taking Risks
Courtesy ARMA International

In your role as a fellow of ARMA International, you’ve helped to connect organizations with practitioners who truly understand the discipline and benefits of Information Governance. How has this evolved over the years and what steps do you think organizations like ARMA and the ICRM need to keep taking to remain relevant?

This is a great question as the core IG professional organizations have been dealing with an identity crisis for some time, and still struggle to have a clear and concise “elevator speech” on mission and value. IG, while it has a wide breath, has many in the industry confused, and still is a term that does not universally resonate with senior management. These associations have tremendous value and passionate support but numbers speak volumes and membership and conference attendance have been decreasing for years. We are seeing the technology vendor market taking over a leadership role and may serve as the new defining force in setting direction and guiding the industry – self-serving yes but it could be what is needed going forward. I am not concerned about relevance as it will continue to be all about information and technology, and the management, protection and leveraging of information asset. While the role of a traditional Records Manager may not continue to be relevant, I don’t find it concerning – the relevance is in the work and it evolves…

Read the entire interview and more in my new book on leadership in the information age, Tomorrow’s Jobs Today.

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You Think You Don’t Know Enough About GDPR? You Are Right and Here’s How

By Rafael Moscatel, CRM, IGP on

The EU has taken the first step in protecting the data and privacy of its residents. Through the enactment of the General Data Protection Regulation (GDPR), people are now able to have the protection they are looking for online. This means changes for businesses everywhere that are planning to reach consumers in the EU.

Companies need to look at the way that they are handling the personal data of their customers and have an action plan in place to ensure their privacy is protected. Without a strong understanding of what the GDPR means and how it affects your business, you could find yourself in a situation with the EU that you didn’t count on.

Fifteen members of Forbes Technology Council discuss some of the more unexpected consequences of the new GDPR regulation. Here’s what they had to say:

1. Restriction Of Privacy And Innovation

GDPR is the latest version of Y2K compliance — long on speculation and fear, short on reality. In my opinion, regional enforcement of global technology is an impossibility and will restrict — not enhance — privacy, freedom and innovation. The result will be regions of non-compliance (GDPR havens), enormous expense and uncertainty. – Wayne Lonstein, VFT Solutions

2. Roadblocks For Blockchain Data Storage

GDPR could impact the decisions and data sets being stored and collected in emerging private and public blockchains. This may create roadblocks for companies looking to embrace blockchain to store any data that may fall under GDPR. – Aaron Vick, Cicayda

3. Opt-In Fatigue

One of the most unexpected consequences of GDPR is the wave of new regulations in jurisdictions outside of Europe, including California, New York and perhaps soon in Asia. Another unintended impact is “check the box” fatigue where opt-in consent language is presented so frequently on websites and apps that consumers don’t read the consents and just check the box, waiving their privacy rights. – Silvio Tavares, CardLinx Association

4. Poor Customer Service

One GDPR byproduct distortion or unintended consequence is excessive regulation leading to poor customer service. The pendulum has swung too far and will be moderated by citizen feedback. – Jeff Bell, LegalShield

5. Small Businesses Getting Hurt

The companies that are best prepared for GDPR are the big ones: Facebook, Google, Amazon — those that have the money to pour into their tech and legal teams for ultimate compliance. The small and medium-sized businesses, however, may be less prepared, making them more vulnerable to potential fines and penalties. – Thomas Griffin, OptinMonster

6. The Slow Death Of Free Services

If a service is free, then your data is the product. We all love using Facebook, YouTube and the many other social media platforms. However, we fail to realize how these businesses operate. If regulations strangle business, then the alternative is a paid model. Just look at YouTube and how it’s strugglingwith its paid subscriptions. – Daniel Hindi, BuildFire

7. Talk About Similar Regulation In The U.S.

The most unintended consequence has been the multitudes of discussions about a similar impending regulation in the U.S. In fact, reading between the lines of Facebook’s testimony to Congress, it is clear to me that tech leaders realize more care ought to be given to sensitive data, and users should have more rights. They are preparing for coming regulation stateside. – Michael Roytman, Kenna Security

Read more on Forbes:

https://www.forbes.com/sites/forbestechcouncil/2018/08/15/15-unexpected-consequences-of-gdpr/#2ce5537f94ad 

 

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Using Blockchain for the Common Good – An Interview with Ashish Gadnis of BanQu

By Rafael Moscatel, CRM, IGP on
BanQu - Information Governance Perspectives

Using Blockchain for the Common Good – An Interview with Ashish Gadnis of BanQu

Sixth in a series of in-depth interviews with innovators and leaders in the fields of Risk, Compliance and Information Governance across the globe.

Information Governance Perspectives - Ashis Gadnis of BanQu discusses Blockchain

Ashish Gadnis is CEO of BanQu, Inc. and a recognized thought leader in the blockchain community. He chairs the Financial Inclusion Working Committee for the Wall Street Blockchain Alliance and travels the world explaining how this revolutionary new technology is transforming the way we think about supply chain economics. He holds an MBA from the University of Minnesota’s Carlson School of Management and graduated from the Global Leadership and Public Policy program at the Harvard Kennedy School of Government. I spoke with him this July about blockchain, business administration and professional development.

Ashish, you recently spoke at the MER conference where the theme was “Records for Humanity,” how data governance impacts the human condition. And your company, BanQu, offers a unique solution to the challenge of extreme poverty by leveraging blockchain. With BanQu, people ensure their economic identity with an immutable record of their transactions in a system benefiting the entire supply chain. But how exactly do you, your clients and big brands set about prioritizing and realizing these goals?

Over the last two and a half years we’ve realized that 2.7 billion people, that includes refugees displaced and those in extreme poverty zones, participate in some sort of a supply chain. That can mean you’re the poorest farmer in Congo growing coffee, cacao or shea butter, you know, the ingredients that go into cosmetics, and your contributions show up in brands like eight dollar lattes and expensive body lotions. And in examining this, we realized that that current models for getting people out of poverty have failed. Those models have failed because they look at the ability to help people out of poverty separate from enabling people in poverty to participate in the supply chain. And so we actually took the other route. And nobody had ever done it. We said, “What if the people who are absolutely in that last mile, if they get to equally participate?” Then the value for the brand is suddenly more relevant.

Let’s use a simple example. If you’re buying cacao in Ghana and you’re a large chocolate company, there’s a good chance today that your last mile farmers are extremely poor and also invisible. No matter much traceability, transparency or fair trade you implement, until and unless that farmer can participate in his data, to know for example “I’m selling 40 kilos every other week to this big brand,” then that farmer will continue to live in poverty. And this is kind of a long answer, but the detail is important because that poor farmer today has everything stacked against him or her, especially if conditions are so rough. I was just in Zambia a week and a half ago and I saw firsthand some of this problem, which was that women farmers have to borrow at a higher price point.

Women farmers are always at the short end of the stick because they’re not allowed in many cases to prove their history. So what happens if you happen to be selling 40 kilos upstream and there are seven middlemen… after I sell my coffee… somebody picks it up, then brings it to somebody else, the next one goes to the warehouse and eventually you’ve lost the ability to track. And while the internet has come to people in poverty it hasn’t pulled people out of extreme poverty permanently. There’s mobile money, there’s big data, AI, etc., but none of those models actually have ever allowed that mother, that farmer, to participate equally.

When I say participate equally, it’s very basic. To me participate equally means that one, she has a physical (stored digitally) copy of that transaction that nobody can ever steal or manipulate. Two, she has the ability to prove her transaction history which legitimizes her existence in that supply chain. And three, it allows her to now leverage that data in a way that reduces her cost of borrowing. It allows her to be portable. That’s how we decided to look at blockchain and nobody in the world has ever done this. People keep talking about how they’re going to use blockchain for good and we’re the only ones doing it everyday, taking a commercial approach while being simultaneously deeply purpose driven. We started a for profit, for purpose software company and now the largest brands are coming to us because it solves two sides of the problem for them. One side is that the supply chain now becomes more cost effective and efficient. They get better visibility into the supply chain in terms of quality, market access and forecasting which enables an ecosystem for crop insurance, climate protection, education. And the other side of the coin is now they can start addressing issues like gender equality, labor rights and other important issues.

Read the entire interview and more in my new book on leadership in the information age, Tomorrow’s Jobs Today.

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Emerging From The Dense, Digital Fog – An Interview with Dr. Ulrich Kampffmeyer

By Rafael Moscatel, CRM, IGP on
GDPR - General Data Protection Requirement - Information Governance Perspectives

Third in a series of interviews with leaders in the fields of Risk, Compliance and Information Governance across the globe.

IMG_992_kff_400x400

Dr. Ulrich Kampffmeyer is the Managing Director of Project Consult in Hamburg, Germany and a renowned expert on digital transformations, business intelligence and enterprise content management. I had the opportunity to sit down with him in May and discuss the GDPR, artificial intelligence and social issues emerging from the dense, digital fog we all find ourselves in.

Ulrich, you write and teach extensively about the cultural and social changes in work environments that are a direct result of the emergence of digital transformations. Now that data is at the fingertips of everyone, what changes should society expect that the business world may have already?

The pace of digital transformation accelerates day by day. Cloud technologies, artificial intelligence, IoT and other developments are happening so fast that there is a danger they’ll get out of control. The mightier AI becomes the larger the danger that it gets uncontrollable. Consider Soshana Zuboff (one of the first tenured women at Harvard Business School) and her three laws:

  1. Everything that can be automated will be automated.
  2. Everything that can be informated will be informated.
  3. Every digital application that can be used for surveillance and control will be used for surveillance and control.

Neither our businesses or society are currently prepared for this change. Just have a look at the GDPR discussions. Data protection as general necessity, data safety as the requirement for continuity, data privacy by default, information governance to keep control, keep the value, keep information accessible – these are basic requirements that should not be ignored like in the past. Future historians will call our era the dark age of the early information society.

You spent quite a bit of time at the Fraunhofer Institute developing imaging systems and processes to support archaeological studies. Given that images provide so much of the fuel for artificial intelligence engines, do you envision some of our older legacy systems and indexes ever providing value to future AI efforts?

In the mid-80’s I worked on pattern recognition, image processing, database systems and expert systems for archaeologists and prehistorians. Too early. Today, taking a computer, drones and sensor systems to an excavation is standard. The capabilities of software, hardware and self-learning algorithms are far more sophisticated than in those days. But lets consider so-called old fashioned methods of organizing information. You mentioned the terms “legacy” and “indexes.” Metadata is not legacy. It is a question of quality, control and governance. Controlled metadata, vocabularies and taxonomies are of special value to big data analytics, artificial intelligence and machine learning. Controlled data sets work as guide poles to train new technologies with high quality information. This is important for automated indexing when capturing information, when sharpening enterprise search for qualified results, and managing your repositories in regard to compliance requirements. Especially when it comes to compliance, straightly organized high quality information is an asset. But AI will change the game as well in the near future. Currently classification schemes and file plans are developed manually by academic rules. In the future software will analyse all information and organize itself by protection guidelines, user models, processes, value, retention.

This series of interviews with global leaders in information governance, risk and compliance seeks to find common values and themes in these disciplines across disparate cultures. I know that you are major advocate of standardization. Are there one or two common threads that run between all of the projects and people you’ve worked with that you also believe should be universal aims?

Read the entire interview and more in my new book on leadership in the information age, Tomorrow’s Jobs Today.

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Business Processes Ethics Information Technology Privacy

Digital Bondage and the Fallacy Of Work-Life Integration

By Rafael Moscatel, CRM, IGP on

Forget your elder’s sage advice on maintaining a good work-life balance. There’s a new patently absurd approach (promoted here by the time-strapped PhD’s at Berkeley Haas), and it’s spreading like wildfire throughout the business world. They call it… “Work-Life Integration!”

Digital Bondage

The term “Work-Life Integration” is so misleading because at this point we’re all enduring an increasing degree of overlap between our personal and professional lives. It may be sold to us as “convenience” but much of it is not exactly “optional.” This obsessive and all-in-one approach to time-management ends up usurping the little personal, spontaneous and family time we still have left.

It reminds me a little of Chris Rock’s famous bit on “Job v. Career.”

But not everybody is as fortunate as Chris and there’s a bigger impact to his lifestyle than he’s letting on in the above clip. And so “Work-Life Integration” also makes me think about Cecil DeMille’s classic The Ten Commandments and the famous scene where a worker is about to be trampled by a giant stone moved by “her colleagues.” Moses’ character, played by Charlton Heston, comes down from his managerial pedestal to save the poor soul, who later turns out is his own Mother! It’s a metaphor for how easily, often and unfairly, we as society, put work before family, friends and for believers, even God. And when it negatively impacts others it is arguably immoral.

I was most recently educated on this 24/7 mindset by an executive who boasted, “Say I’m on flight to Hawaii with my family for the weekend, and I’ve got to approve a purchase order for half-a-million. I can do it right here from my iPhone!” Well, that’s nice, but it highlights the disconnect between those who literally have the world at their fingertips and those who get interrupted with email from their boss on the weekends. The same technology fix that feeds the workaholic is now invading the space of almost everyone, not just the guy or gal with a “career.” It’s affecting their partner, their children, their social circle, people on the road. And in many cases it is invasive, counter-productive and unhealthy for the family and the self. Do we really want to live in digital bondage?

In many ways, this digital bondage is reminiscent of the days when men and women of all ages built the Pyramids until they dropped dead. Sure, the Pyramids still stand as a testament to architecture and ingenuity, but to many they will also always represent a chapter in history when there was seldom a break from work. Luckily today we have a choice.

We must stand firmly behind the importance of rest and personal space. Sure, working remotely through technology has given us flexibility. There’s no denying that. But half-baked ideas like “Work-Life Integration” have adversely impacted the very relationships and working-conditions they were meant to improve.

Some in the Jewish faith believe that one of the Ten Commandments, to observe a day of rest on the Sabbath, is a cornerstone of not just spiritual growth, but what ultimately may lead to success in other areas of one’s life. Most cultures share this important value but as it erodes across the globe and the lines between work and rest are blurred, we all suffer.

Stay off the devices this weekend as much as you can. Find true balance by freeing yourself from digital bondage.

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