What is PrivacyOps?

The multi-disciplinary practice to automate compliance with privacy regulations. For responsible custodians of people's data.

PrivacyOps Book

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PrivacyOps - Automation & Orchestration for Privacy Compliance

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PrivacyOps is the combination of philosophies, practices, cross-functional collaboration, automation, and orchestration that increases an organization’s ability to comply with a myriad of global privacy regulations reliably and with greater speed.

It evolves an organization from traditionally manual methods across various functional silos to full automation in a cross-functional collaborative framework for most aspects of privacy compliance. The reliability and responsiveness to subjects enhances an organization’s trust equity and makes it more trustworthy with sensitive personal data.

How PrivacyOps works

Under the PrivacyOps model, the legal, IT, data, development, and information security teams are no longer siloed in terms of privacy compliance. They operate within a common framework that allows them to communicate and collaborate for most important practices of privacy compliance.

The teams use automation in all privacy practices that historically have been manual and slow, giving them better real time understanding of privacy issues, readiness and compliance needs. Automation in linking of personal data to its rightful owner and purpose of user consent provides real time view of regulatory risks and prepares teams to respond to data subject requests or notify selected data subjects quickly in case of a data breach.

PrivacyOps brings secure collaboration to bear on sensitive personal data, eliminating the need for historical methods of sharing sensitive data and assessments over insecure communication channels for compliance and review purposes. Sharing of personal data across communication channels like email and generic messaging creates further PI sprawl.

Teams use orchestration and robotic automation to fulfill data subject requests reliably at a much faster pace, reducing cost and compliance risk.

General building blocks of a PrivacyOps framework includes:

PrivacyOps Framework

System of
Engagement
and Collaboration

Brings collaboration to the sensitive personal data and privacy related information in a secure platform, rather than sending personal data over emails and messaging systems for review and approvals.

System of
Insights and Analytics

Using AI, bots and intuitive visualization, it provides realtime insights about all aspects of privacy compliance,including PI data risks, DSR fullfilment status, regularity compliance posture, vendor risks, user consent etc in one place.

System of
Record and
Knowledge

Keeps all important, privacy related information such as assessments, PI linkage graphs, data maps, regulatory templates, vendor documents, etc., in one place.

System of
Automation and Orchestration

Automates and orchestrates complex tasks like DSR fullfilment, PI Data linking, consent lifecycle management, recording audit record etc to reduce cost and avoid penalties.

Benefits of PrivacyOps

Following are some of the benefits of cultural change, automation, orchestration and collaboration enabled by PrivacyOps.

Better understanding

A better common understanding of data privacy regulatory obligations and compliance requirements across all functions of the organization. Teams get a better view of the privacy risks lingering in personal data stored across systems or in the organizational practices related to personal data. A common PrivacyOps framework that correlates information from various privacy practices, such as readiness assessment, data discovery/linking, consent management and DSR fulfillment can provide a better overall understanding of privacy posture and regulatory risks to the organization.

Real time oversight of privacy risks

An up-to-date real time view of the data privacy risks that may exist inside the organization, based on how data is collected from subjects of various residencies, how consent is collected along with data, how personal data is shared internally and externally, and where it is stored.

Agility

Move at high velocity to accomplish and maintain compliance with ever-changing privacy regulations across various geographies. Respond to data subject requests swiftly from various geographies with ease, providing a delightful and trust-building experience to subjects. Quickly notify affected subjects of any security incidents and breaches, as required by various privacy regulations. Reduce time spent on manual efforts, increasing productivity and effectiveness.

Reliability

Ensure that various aspects of privacy compliance across the organization, including internal assessments, vendor assessments, PI data linking, consent understanding, fulfillment of data subject requests and compliance records are reliable. Greater reliability builds trust with subjects, avoids regulatory penalties, and enhances the organization brand.

Scalability

Operate various aspects of privacy practice at scale, across multiple applications, with large data sets, across different geographies and diverse stakeholders and regulations.

Increased Expertise

Increase the privacy understanding and expertise of diverse team across the organization by having them spend more time on expert-level tasks rather than manual and mundane tasks related to assessments, DSR fulfilment, data discovery and subject communication.

Improved Secure Collaboration

Enable effective collaboration across diverse teams, from legal, privacy, IT, cybersecurity, marketing, development and support groups. Enable collaboration around sensitive PI data, without the need to share sensitive PI data over generic email and messaging tools.

Improved Brand

Develop a unique market position with trust-based relationships with both prospective and current clients. Providing transparency on data handling practices and swiftly fulfilling access requests builds trust. The prospect of implementing a secure and transparent PrivacyOps infrastructure nurtures further awareness of the emergent need to adopt such practices on an industry-wide scale. This coincidentally serves as a motive in developing standardized PrivacyOps practices and therefore, a possible market niche for a singular platform.

Why PrivacyOps Matters

The use of software and data is revolutionizing the world and all aspects of life. Increasingly private and personal data is at the center of crafting more personalization for the subjects. Organizations increasingly hold more personal data of various kinds, including identity, activity, financial, medical and genetics data. This implicit or explicit sharing of personal data by subjects sits on a delicate fabric of trust that, if compromised, causes serious harm to the organization brand, as well as opening it to regulatory fines and lawsuits.

With PrivacyOps, multiple teams collaborate and make full use of automation and orchestration to understand privacy posture, eliminate privacy risks and fulfill privacy obligations swiftly. It engenders trust in the organization and makes it easier to have confidence in.

How to adopt a PrivacyOps model

Adopting PrivacyOps requires a cultural mindset of collaboration across traditionally siloed teams to accomplish privacy compliance. PrivacyOps helps remove the silos between various teams, such as legal, compliance, IT, cybersecurity, marketing and development. It enables every stakeholder to complement their expertise with that of other team members. Maximum use of automation and orchestration brings efficiency, reliability and velocity in keeping up with compliance with multiple privacy regulations and fulfilling subjects rights for data requests.

Following are some of the critical elements required for adopting a PrivacyOps model.

PrivacyOps - Personal Information Data Linking Automation

PI Data Linking Automation

PI Data linking is the process of discovering personal information stored across all systems and linking it to the owner of the personal data. With large amount of structured and structured data across vast variety of systems in an organization, this aspect has to be automated. Static data flow maps collected from stakeholders are not sufficient and must be supplemented with automated data flow mapping. Some data can be linked ahead of time and some can be linked on-demand at the time of building a report or fulfilling a data subject request. In either case, enabling full automation to accomplish this link between the PI data and the owner become the foundation of many other privacy compliance task. PI data linking must be across all systems, including internal systems, third-party systems, SaaS and IaaS infrastructure.

PrivacyOps - Data Subject Request Fulfillment Automation

Data Subject Request Fulfillment Automation

DSR fulfillment is the process of receiving data requests from subjects and taking the necessary steps across all internal and third-party systems used by the organization to comply with the legal request of the subject. As personal data of the subject is spread across any number of data systems managed by different stakeholders, manual ways to fulfill the subject requests are highly inefficient, costly, prone to error.

If the volume of subject requests increases due to internal or external events, manual approaches to fulfilling DSR obligations can bring operational hazards and compliance risks.

DSR fulfillment automation is not simply about capturing subject requests and assigning them manually to different stakeholders, based on some static rules. It is the process of full automation of discovery of systems and objects carrying subjects’ personal data, assisting system and object owners by orchestrating DSR fulfillment on these systems, and providing the completed reports back to the subject after taking necessary approvals from the legal stakeholders.

PrivacyOps - Secure Privacy Portal

Secure Privacy Portal

As privacy regulations give rights to subjects on their personal data that organizations collect either directly or indirectly, the organizations must have a secure way to collect subject requests, verify the identity of the subject, provide personal data securely to the subject and keep compliance records to defend against any legal suits. Providing such a secure privacy portal to the subjects helps build trust, promotes a delightful user experience, and facilitates automation for user identity verification and DSR fulfillment.

PrivacyOps - User Consent Lifecycle Management

User Consent Lifecycle Management

Most privacy regulations prohibit processing personal data unless the organization can establish legitimate interests or the data subject has consented to the processing. Furthermore, regulations also specify that consent must be freely given, should be informed and unambiguous. Depending on the scenario, consent collection may be explicit (opt-in) or optional (opt-out) and if the organizations choose to rely on consent for any part of the processing, it must also be prepared to respect that choice and stop that part of the processing if the individual withdraws consent. In other words, if an organization wants to process data lawfully and are relying on consent as the lawful basis for that processing they have to implement a robust consent management system.

To establish lawful basis for processing personal data through consent, organizations must have methods to display unambiguous notification messages and at every consent collection point. Once collected, consent should be linked to unique identities and personal data records within the environment and it should be tracked through its lifecycle so that appropriate remediation steps can be taken when the data subject withdraws consent.

PrivacyOps - Breach Notification Automation

Breach Notification Automation

Many privacy regulations require that in case of a data breach or theft of sensitive personal information from an organization, all impacted subjects must be notified in a short amount of time. For example GDPR breach notifications within 72 hours.

To comply with such a short timeline for notifying impacted subjects, organizations must have methods to find PI data stored in a variety of systems, link PI data to its rightful owners, and have a playbook in execute automatically to create a shortlist of impacted subjects and notify them through secure methods.

PrivacyOps - Privacy Assessment Automation

Privacy Assessment Automation

Privacy regulations require that all internal systems carrying personal information go through an assessment process to understand gaps against the regulations and put controls in place to fill them and comply with the regulations. These assessments must be updated on a regular basis. Multiple stakeholders typically must be involved in understanding gaps and tracking new controls to be put in place.

Performing these assessments over spreadsheets and emails is tedious, time consuming, prone to errors, and is hard to track for the great number of systems and processes involved. Sharing selective assessments with third parties manually over emails is inefficient.

Adopting a system-of-knowledge that provides audit templates for various privacy regulations, a system-of-record to keep all assessments in one place, a system-of-engagement the bring all stakeholders in one place to provide their input and a system-of-sharing to share assessments with external parties, makes the assessment process agile, easier to track, and up to date.

PrivacyOps - Vendor Assessment Automation

Vendor Assessment Automation

Privacy regulations require that all third parties with whom the personal information is shared go through an assessment process to understand their gaps against the regulation. These assessments must be updated on a regular basis.

Performing these assessments with a large number of vendors over spreadsheets and emails is tedious, time consuming, prone to errors and is hard to track.

Adopting a system-of-knowledge that provides audit templates for various privacy regulations, a system-of-engagement to invite all vendors in one place to complete their assessment and a system-of-record to keep all vendor assessments and proof compliance in one place makes the vendor assessment process agile, easier to track and up to date.

PrivacyOps - Vendor Privacy Risk Monitoring

Vendor Privacy Risk Monitoring

As vendors hold important personal information, it’s important to monitor independent privacy ratings of vendors based on how they collect, store and exchange personal information with others, how they respond to data subject requests, and whether they have had any recent data breaches. These independent privacy ratings of vendors supplement the responses vendors provide as part of vendor assessments audits.

Having a process in place to monitor any decline in independent privacy ratings of a vendor below a certain threshold enables an organization to deal with privacy issues swiftly and responsibly.

Collaboration

Complying with privacy regulations requires collaboration across multiple functions, including legal, IT, cybersecurity, marketing, product development, etc. To avoid the sprawl of PI data, collaboration must be brought into the PrivacyOps framework, versus sending personal information to other stakeholders over email and generic messaging tools. PrivacyOps requires a built-in system of secure collaboration that helps minimize data sprawl caused by distribution of sensitive personal data for reviews and approvals.

Automation & Orchestration

Automation and orchestration are at the epicenter of enabling agility, reliability, scalability and manageability for PrivacyOps. It also enables functional teams to focus on higher-level issues of privacy compliance, versus spending time and effort on mundane manual tasks.

PrivacyOps Components
PrivacyOps Book

Download the book today!

PrivacyOps - Automation & Orchestration for Privacy Compliance

Request a copy

Available in PDF