The Key to GDPR Compliance? A Data Privacy Program
If your organization does business in Europe or works with European clients, you're probably aware of the EU’s work to create a standardized set of data protection regulations. This framework, known as GDPR (General Data Protection Regulation) gives individuals greater control over their personal data as well as imposing specific rules on organizations that collect and manage that data.
While the specifics of GDPR can seem overwhelming, it has a simple goal: to preserve the privacy of consumer data.
To achieve and maintain GDPR compliance, a data privacy program is necessary to help an organization control the flow of information, prevent breaches, and create processes that will be set in place should certain data privacy-related events occur.
First Steps: A Data Privacy Overview of Your Organization
The first step to getting started is understanding where your organization currently stands in terms of its data privacy governance.
What protections have been put in place? Are all team members adhering to the current policies – and are those policies sufficient?
A thorough review of current information management practices is necessary to help paint a picture of how compliant your system is with GDPR specifications and shine a light on any red flags or areas that may need correction.
Building a Data Privacy Program
Although an overview will give you a general idea of the data flow and privacy policies within your organization, the only way to get an accurate picture of the potential risks and your overall GDPR compliance is to start from the ground up to build or improve on your current data privacy program. This process will include:
1. Gaining Insight on Data Discovery
As part of a data privacy gap analysis, it’s essential that you identify all data considered “personal” under GDPR's requirements and discover where that sort of data is currently being processed and/or stored. This includes information that ranges from names and addresses all the way to an individual’s occupation, gender, or health-related information.
2. Understanding Your Organization’s Privacy Architecture
Next, illustrate the existing environment by conducting a data mapping exercise to indicate where sensitive data currently lives, as well its various paths during data flow. In addition to documenting all assets, be sure to include applicable security measures throughout the organizational architecture such as firewalls and other safeguards.
3. Data Mapping That Extends to Third Parties
Privacy data isn’t only at risk as it travels within your organization; it’s also subject to breach when being transmitted to and from third parties. Because of this, utilize a detailed, drawn-out map that includes how data flows not only inside of your security infrastructure but also any third-parties you do business with or share information.
4. Implement Procedures and Policies to Protect Customer Privacy
Once your data privacy architecture is mapped out, you’ll have a better understanding of what data is vulnerable and where it’s at risk. Are there areas where your security architecture is weak? Is your organization following required GDPR procedures such as notifying individuals if their data is compromised? Changes or additions to current policies and procedures may be necessary to bring your current data privacy program up-to-date.
As you analyze your current program and identify areas that need changes remember that GDPR wasn’t created to protect your organization; it was put in place to protect consumers’ rights and private data.
With this perspective in mind, what protections can be put in place to mitigate the risks not only to your business but to your customers as well?