Information Management – 4 steps to conducting a GDPR compliance audit. This story written by Majken Sander was published in Information Management in August 2017
Many organizations are starting to feel stressed and perhaps a bit confused by the General Data Protection Regulation that is quickly approaching us and will hit May 25, 2018.
Indeed, the more I talk to companies, the more I hear the same question: “What exactly is it that I am supposed to do?”
The answer is, 'plenty.' But first, it’s essential that we understand what we’re dealing with.
If you’ve worked with regulations such as Sarbanes-Oxley (SoX) or Health Insurance Portability and Accountability Act (HIPAA) before then you have likely heard about GDPR. And like with those other regulations, the ramifications of not being in compliance when it goes into effect are severe.
GDPR views each and every person that an organization interacts with (either inside or outside the company) as a center cog and every interaction as a digital footprint that requires handling “the GDPR-way.”
Note to U.S. organizations: even if your company is based outside the EU, you may still need to be GDPR compliant. What determines the need for compliance is who you hold data on. If you collect data on any EU citizen, you are subject to the regulatios. This includes selling or shipping an item to someone in the EU, or even shipping inside the U.S. but the person doing so is using a credit card from the EU.
GDPR touches upon how we use and store data, for how long and for what purpose. It addresses how we inform individuals about which data we hold, how to anonymize the data and how we delete it.
It also requires control over scenarios such as who responds to the request from the consumer exercising their right to be 'forgotten' and to make sure that it’s dealt with within reasonable time. The fact that some organizations are now required to hire a data protection officer (DPO) suddenly means that GDPR takes on an entirely different level of importance. With that, GDPR guidelines requires that many organizations do a comprehensive business process overhaul.
With that in mind, some organizations might consider shutting down a system or platform as “the solution,” because they feel as though they cannot oversee GDPR and don’t want to risk being imposed with a fine. But how many days are you willing to run your business without your HR system or your BI and analytics platform? You built and implemented them for a reason.
Starting Line - The Audit
Suffice to say, you’d rather not shut down systems and would prefer to become GDPR compliant. The next question is what do you do? To begin, a healthy audit is required, so you start by asking yourself these questions:
1. What data does our company hold?
Awe, that’s an easy one you think. You list the different systems that come to mind: ERP, CRM, HR. But then you wonder, “What is the name of the system we use for data analytics?” You then realize that it’s not just the system's name that needs to be documented, but the entire data model inside the system.
2. Where does our company store this data?
Maybe you’re lucky enough to be able to write a complete list of your company’s IT systems. With that list in hand, you ask your IT department where the systems are that store their data. They could very well get back to you with the names of other systems that aren’t even mentioned on your list. Your search would prove that there are more systems to document and account for than you thought.
3. What is our data used for?
“It’s used for business operations,” your finance person might answer, but will neglect mentioning it’s also used for budgeting, forecasting, BI and analytics. Finance might even add a few more systems to your list, since they will include the data warehouses and analytical tools they use.
If you press them to define what they mean by “business operations,” they’ll likely say something like, “You know, reporting, analysis, and some self-service BI.” Then, they’ll look at you and ask whether you really need a complete list of where every little piece of data is used? With GDPR coming at you, you know the answer to that question.
4. Who has access to our data?
As the list of systems and data usage has grown from your inquiry, your certainty about who has data access has faded. The answer doesn’t just cover access to the main company systems, but also data that’s being pulled into separate systems for data analysis and visualizations, and even data that’s just being fetched into Excel and later emailed “to whom it may concern.”
So who has access to data? Probably a lot more people than you think. Asking “Why?” could very well turn your list into a novel and may even include some department’s dream of eventually using this data for a certain purpose.
Viewing GDPR as a Golden Opportunity
Clearly, the more people you ask within your business, the longer the list will be of systems and the different kinds of data usage. Everyone from the C-Suite to the DBA is looking for resources, man-hours, tools and platforms to help them with compliance.
Maybe, the answer isn’t about adding as many resources as possible to cover the most mileage. Instead, perhaps you should be looking for different approaches that will enable you to reach GDPR compliance. For instance, consider transforming this work item as an opportunity to strengthen your management control of all your data management platforms and to work smarter from this knowledge.
The race is on to become GDPR compliant and there’s lots of ground to cover. With May 25, 2018 headed our way, all organizations need to pick up speed. GDPR compliance requires many tasks but to get to the finish line it all it starts with the comprehensive audit, and the realization that it is not just about data, but about business processes and the continued wish to stay data-driven as a business.
(Note: The audit is only the start of the GDPR process. In part two of this series on becoming GDPR compliant, I'll take a look at some of the business processes needed so that all stakeholders can exercise their right to access and view data.)