Governance, risk, and compliance software and strategy encompass several risk domains that have expanded and specialized as businesses have evolved. Vendor risk management has escalated to be a strategic enterprise risk. Organizations have decentralized operations to optimize their supply chain and invest in a variety of tools to enhance performance and productivity.
As risk disciplines have specialized, overall risk management practices remain siloed to the second and third lines of defense (risk managers and auditing professionals). Translating risk to outside the second and third lines in a way that communicates both potential business impact and personal implication, is an ongoing challenge. Because businesses are operating faster than ever, this model is not sustainable at scale.
In the last five years, privacy has emerged to play a critical role in operations and enterprise risk. The digital transformation changed the way businesses operate, impacting how organizations engage with customers, and execute internally. Data breaches and compliance laws such as the GDPR and CCPA have escalated public realizations in understanding the value and associated risk of personal data shared across businesses. With global regulations in place and more coming into effect as privacy practices mature, companies have shifted the way they operate. Organizations must take a very intentional review of the data they collect and how that data is processed across departments to comply with emerging privacy regulations.
Although privacy is a newer risk domain, privacy practices have excelled at traditional risk management execution. Here are some of the best practices implemented in successful privacy practices.
Translating Risk for Cultural impact
Privacy compliance has impacted organizations at a cultural level. A key contributing factor to this is that individuals, regardless of their position, understand the risk. Answering the question, Why is privacy important? Privacy or risk managers can often communicate the impact through a few anecdotal scenarios or references to significant data breaches. Business stakeholders, irrespective of the role, understand the impact at an intimate level because people can relate the exposure of not having control over your personal information.
First-line of business users need to take a level of ownership in executing risk management operations. To properly motivate this type of action, the business needs to understand the context of risk within the scope of their business; this is where organizations need to translate risk to promote a risk-aware culture across their traditional three lines of defense.
Businesses who can successfully deliver meaningful risk information help foster ownership of proactive risk management activities outside of the second line because the value is clearly understood. The personal level of context and applicability can be a strong motivating factor for stakeholder engagement. Tailored role-based access and experiences can help support this in governance, risk, and compliance software platform.
Privacy practices have a laser focus on a specific data set (any data that is personally identifiable for an individual). Regulations such as the GDPR are highly accurate and clearly outline the roles and responsibilities of controller and processer. The parameters around proper business operations, particularly collection and processing, are well defined and detailed as to what is acceptable for a legitimate interest in collecting personal information. It’s very clear cut you need a controller, processor, DPO, and within each role, there is a clear designation of responsibility.
In tandem with the need for appropriate context of risk impacts, stakeholders need roles and duties with respect to executing and taking ownership of mitigation efforts and opportunities. Across the business, different functions are in the position to support activities at different stages. Risk managers understand the risk and need to communicate it. The line of business stakeholders is in the position to execute mitigation activity promptly. Leadership is in control of the budget and the overall authority of the program as a whole. These interdependencies must be acknowledged and defined in line with your business objectives. Structured workflow and triggers can help engage the appropriate stakeholders for action from policy approval to risk mitigation within your governance, risk, and compliance software platform.
To implement practices, Privacy By Design involves significant consideration across departments because of the focus on processing and providing access to data both internally and externally. Many organizations have employed a new specialist here, Privacy Officers. These professionals need to work closely aligned with marketing, incident and security operations, IT, and also procurement or vendor management team, among others. Privacy regulation requires a horizontal initiative across disciplines.
Following some of these best practices in privacy management, governance risk, and compliance management can support a strategic and resilient GRC program. With a well-guided strategy, and agile governance risk and compliance platform, organizations can transform operations across cyber risk, vendor, operational and enterprise risk management.
Learn more about OneTrust GRC and our solutions for Privacy Management. OneTrust GRC takes a truly integrated approach to governance, risk and compliance software, to extend risk to the line of business users, and seamlessly tailor your business and security be design processes with supported workflow functionality.