OUR THINKING
Implementing an Effective Data Privacy Practice
Compliance to global privacy regulations like General Data Protection Regulation (GDPR), California Consumer Privacy Act (CCPA), Privacy and Data Protection (PDP) and incorporation of data privacy principles like data subject rights, consent management, and privacy by design are extremely critical not just for compliance and audit purposes but also for safeguarding individual interests.
An effective data protection practice helps clients better defend their operations against insider threats, data exfiltration, and ransomware, to meet compliance mandates, mitigate risk, and safely rollout innovative cloud initiatives.
While most organizations have invested significantly in Data leakage Prevention (DLP) and the encryption space, an end-to-end approach to managing the security of data from source to destination is vastly missing.
3 pillars of data security strategy
A sound data security strategy comprises 3 pillars: plan, build and run.
Plan
- Define what is critical data and why is it important to your organization
- Identify process and data dependencies and understand the data flows
- Discover and classify where sensitive data is located
- Identify program gaps and prioritize the remediation options
Build
- Implement and baseline data protection controls
- Build-out and help mature the data protection program
- Normalize tools and operational procedures
Run
- Data policy and threat alert monitoring
- Threat, policy and change management
- Tools and device management
- Incident response
The need of the hour is a holistic approach that begins with:
- identifying data lying in legacy data stores
- classifying the information discovered in various categories
- defining policies on confidentiality using tools like DLP
- applying filters on the information based on access rights to be given using technologies like DRM and encryption
- 360 degree of the privacy compliance management through activities like data subject rights management, compliance, consent management.
Typical IT services involved in implementing a data privacy practice include consulting, systems integration, and managed security services to deliver data-driven risk management programs that optimize resources to protect data. An addition of analytics and cloud expansion can give a seamless extension to the on-prem policies and the same can be achieved using technologies like UEBA and CASB.
We can also include basic security principles, such as assigning access rights based on least privilege and accounting for adequate separation of duties, advanced defense-in-depth techniques that cover technical, operational, and administrative controls, along with appropriate technical architectures that can enforce data protection measures regardless of where the data is stored, used, or processed.
Challenges in implementing a Data Privacy practice
Data provides a critical foundation for every operation in your organization. Protecting and using it securely is central to a zero-trust strategy. Unfortunately, cybercriminals also see the value of data and seek to exploit security vulnerabilities to put your information at risk. Secure data solutions, whether on-premises or in hybrid multi-cloud environments, help you gain greater visibility and insights to investigate and remediate threats, and enforce real-time controls and compliance.
A key challenge lies in protecting various types of data which vary from structured to unstructured.
- Described Data: Content having matches of specific keywords, regular expressions or patterns, and file properties.
- Structured Data: Account Numbers, Credit Cards, Government IDs etc.
- Unstructured Data: Financial Reports, Marketing Plans, Microsoft Office documents, PDFs, etc
- Intellectual Property: Source Code, Product Designs etc.
- Media Files: Scanned or Electronically filled forms, images
The Regulatory aspect
With compliance to GDPR, CCPA and other global privacy regulations gradually becoming mandatory, organizations need to look at both a process driven and tech centric approach to look for the following aspects in managing privacy:
- The role of the Data Controller/Data Processor
- Data Subject Rights Management
- Consent Management
- Data Discovery
- Data Mapping
- Assessment Manager
- Incident Response
- Personal Data Processing
- Rights of Erasure
- Communication of Data Breaches
- Transfer and Disclosure
In conclusion, data privacy is critical to the survival of modern businesses. Leaders should embed data privacy into all processes that have a customer touch point within your company. No matter what size the business is, how mature the compliance program is, most businesses have room for improvement when it comes to data privacy. An ideal approach would be to evaluate your company’s data privacy policies and practices at frequent intervals, to make sure you are utilizing all the resources at your disposal to protect your clients’ data, your business’ bottom line, and your customers’ trust in your company.
Accolite is positioned amongst Texas Cybersecurity Companies.
