85663: Managing Global Compliance in the Wild West of Converging Data Security and Privacy Policy

Project and Program: Service Delivery, Security and Compliance

Tags: Proceedings, SHARE Orlando 2024, 2024

1. Privacy has taken center stage with data security and compliance. In 2023, five U.S. states have issued data privacy laws – California (CPRA), Virginia (VCDPA), Colorado (CPA), Connecticut (CTDPA) and Utah (UCPA). In addition to these laws, 50 bills have been introduced to U.S. state legislatures in consideration of additional privacy laws. These laws are creating a shift in how large enterprises and government entities manage data governance, shifting the stewardship for consumer data and security compliance from IT leaders to the legal stakeholders. a. What’s the risk? In addition to the hit to organizational reputation, the fines are big: Amazon $877 million (2022); Equifax $575 million (2019); Instagram $403 million (2022), and a host of other brand names with fines greater than $100 million including Meta/Facebook, Home Depot, CapitalOne, Uber, Morgan Stanley and Google. 2. In many large organizations, Business teams and IT teams work in silos. The new privacy laws and CxOs transitioning privacy policy from IT over to legal leadership, Business and IT will be forced to work together to create privacy policy strategy and a means to ensure data security by primary users and third-party partners. a. Privacy and data security are converging. Siloed organizations will suffer greater data compliance risk than organizations whose Business and IT leaders work together on the strategy and tactical execution. b. Enterprises are homogenous with a lot of different systems, each with enormous amounts of Personally Identifiable Information (PII). These systems will need to be connected and audited for compliance and potentially forensics in the event of data breach/privacy violation. c. Systems monitoring data access and data deduplication/reduction (per compliance standards), will need to be well connected with a high level of data visibility, and ideally with compliance dashboards matching laws/standards where the data is stored. d. Visibility to data sources outside the datacenter – email, ERP data, other systems that drive services – will also need to be monitored. You cannot limit your compliance visibility to internal databases. 3. Standards and legal restraints are numerous, varying by location. Different state politicians and policy influencers are creating these laws in specific U.S. states but data is everywhere, and managing privacy and data security/compliance is going to become exponentially difficult in the not-too-distant future. a. Managing the data security and privacy policy compliance will be tricky but if you manage with these fundamentals in mind, you should be able to tick all the boxes for most, if not all compliance laws. i. You must communicate across silos. Business and Ops teams are generating and consuming more data than ever before. Since they are less educated on data risk and remediation after breach, communication and education is paramount. Communicate to them that human error is the biggest threat to data security and biggest barrier to privacy policy. ii. Remove the silos from your technology stack as well. Your firewall system data should be correlated with your intrusion-detection system which should be connected to your identity management system. Siloed tech is as detrimental as siloed workflows between Business and IT teams. iii. Your systems need to be connected with visibility rolled up into a single dashboard view so that in the event of a breach or policy violation, you can begin “smart remediation” or breach response with all the data about the breach you need in a centralized location. Without this information in a single pane of glass view, it is impossible to effectively (and intelligently) respond to privacy policy rule such as the right to be removed or to respond to potential data security threat. iv. Have well defined policies for role-based access to data. Your marketing team doesn’t need access to customer account information, but your support team will. The tech you use to help manage privacy should have data anonymization functionality to ensure role-based access is adhered to. v. Only collect the data you need to complete tasks. For customer demographic data, you probably don’t need date/month/year. Year is probably good enough. 4. There are several other fundamentals that we will review in this presentation but the idea here is to make sure the stakeholders for privacy policy (soon to be legal teams) are aligned with stakeholders for data management and security compliance (historically IT and likely to remain so). In this presentation, Infotel will give an overview of consumer privacy and data security and compliance and how to navigate the complexities surrounding both. -- Presented by Tony Perri; Colin Oakhill

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