Data privacy challenges
Today there is no standard methodology to implement privacy controls and comply with the privacy principles obligations that are imposed by the regulators. To comply with the privacy principles, each organization has to derive their own methodology for achieving compliance. The privacy compliance becomes complicated when an organization services customers across multiple geographies where multiple country regulations come into the picture.
Risk based approach would bridge the gap between the privacy principles on one hand, and privacy controls on the other, using a methodology that would help organizations to apply, calibrate and implement privacy requirements appropriately and effectively. A risk based approach to data privacy can help organizations enforce controls based on the risk exposure, in a manner that is flexible and more agile.
Proactive approach to data privacy
Organizations must take a proactive approach to data privacy by creating a data privacy standard and privacy control framework, which can be applied consistently across all functions and geographies to minimize complexity and maximize data protection. Such a framework must provide guidance on what constitutes personal data, what are the requirements for personal data collection, process of managing consent, rules for accessing and using personal data, how to classify and protect personal data, implement the right set of processes and controls based on the risk. This should be followed by creating a data privacy strategy that would help the organizations to manage the privacy of data life cycle right from data collection, storage to disposal.
- Assess your privacy risk posture: Identify the assets, business processes, type of PII being collected, stored, processed & transferred by the organization. Develop a detailed threat profile by considering the various threat actors, threat vectors and the threat impacts to calculate the risk level.
- Ongoing privacy impact assessment: Conduct a PIA for new projects, new application development, existing critical applications that stores or process PII & also to changes to business processes. Automate PIA using GRC tools.
- Build a privacy aware culture: Embed privacy as a central element of value proposition. Build a privacyware organization by conducting privacy trainings, awareness campaigns, and by conducting data privacy events.
- Build product and services with privacy mind: Privacy must be built into products and services by design and by default. Integrate privacy into SDLC lifecycle. Collect data only that which is absolutely needed for processing, to minimize compliance risk and increase customer trust in the product and services. Provide notice, choice and transparency to customer.
- Embrace privacy as a core business value: Look for opportunities to drive value from privacy Bring economic and social value to customers by enabling optimal use for personal information.
- Make privacy a brand differentiator: Organizations that respect the customer privacy, and promote trust and transparency are most successful in the industry. Use privacy as a differentiator to gain competitive edge in the industry.
The road ahead
Data is becoming a fundamental asset in the digital transformation of economies. The increasing use of disruptive technologies has created an unprecedented flow of personal information. Data subjects are becoming increasingly aware of their privacy rights and are rightfully demanding more control over how their personal information is used, shared, and assurances that the privacy of their personal data will be protected.
Organizations across industries and geographies continue to be challenged by disruptive technologies. The boundaries of the digital world are not fully established. The data breaches continue to make headlines and data privacy has become a focal point of discussions in boardroom. Data breaches can do irreparable harm to the organizations brand equity, credibility, trust and customer relationship. It is apparent that there is no one-size-fits-all solution that is available to comply with the ever evolving data privacy regulations. There is a need for organizations to take a comprehensive risk based approach to privacy where globally defined privacy risks are identified and countermeasures are built. This would be far more effective and more likely to respond to cross-border requirements.