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Mind map

Respond

Felicity Scott-Milligan Privacy Program Managment English

Map content

Respond

  1. Respond - aims to reduce organizational risk and bolster compliance to regulations

  2. Information Requests

    • Complaints, issues, concerns from individuals
      • Requires more formality than just reponding to questions.
        • Needs a centralized intake process by which complaints are routed to the privacy team
          • With possible exec engagement if necessary
      • Complaints and privacy rights can be difficult to distiguish - need integration and flexibility if teams are separate to transition
      • Might result in an ethics/complaint process
        • Compliance hotline might be important if internal corruption
    • Requests for information
    • Corrections of inaccurate data
    • Clarifications on privacy matters
    • Subject access requests (UK Data Protection Act and similar international laws.
  3. Handling Procedures

    • Processes/procedures to handle privacy questions/complains
    • As long as privacy resources and the privacy team are communicating with one another to ensure consistency and timely responses there are benefits to being less structured.
      • Preferable to encourage personal to come forward with questions
        • Understand limits of privacy advice that each personal can dispense
          • When first tier responders do not have the answers they must promptly involve privacy team
    • Access
      • Process where internal/external indiv can reach you easily
        • Phone, email, intranet, post box and physical
      • Need a written policy for responding to an access request with adequate verification and consistency in reasoning for granting access
      • Redresss
        • "To set right; remedy"
        • To remove the cause of a grievance or complaint
        • Redress should be clearly defined in your complain process
        • Correction
          • I.e. address change - need clear communication channel to communicate this and documented process
    • Data Integrity
      • Human Failure
        • Need a strong system to educate and resolve i.e. data entry errors
      • Systematic Error
        • Data fields are not aligned - can be costly to fix/store and resolve
  4. Legal Compliance

    • Preventing Harm
      • Allow affected person to protect form identitty theft or other harm
        • I.e. financial loss, reputation or other damage
      • Primary focus when managing any privacy incident is always harm prevention and/pr minimzation
      • Data controller/owner should send out breach notifications not contractor
        • Though contract may pay a set of liquidated damages if they caused the breach per incident
      • Fed guidelines cautions agains notification where risk of little or no harm to avoid confusion
      • Five Factors
        • Nature of the data elements breached
          • Number of individuals affected
            • Likelihood that info is accessible/usable
              • Likelihood that a breach may lead to harm
                • Orgs ability to mitigate the risk of harm
    • Accountability
      • Foster a culture of privacy
      • Implementing appropriate risk controls
      • Effective compliance using these controls
      • Documenting risk mitigation
      • External Audits
      • Accountability during an incident
        • In US many companies fail to comply and they are not held accountable
          • Potentially due to reputational damage
            • Risk of tort liability is NOT significant
              • Owed a duty of care i.e. obligation to prevent access
                • failed to meet applicable standards of care
                  • Proximate to cause damage = causation is difficult to prove
        • Typicall causes of breaches
          • Third Party Hacker
          • Customer Failure
          • Lost or stolen computer equiment
          • Misconduct of customer employees
        • Accountability to a regulator is usually after a significant event that is poorly handled
  5. Monitoring and Enforcement

    • Over time, monitoring and reporting on privacy compliance allows your org to identify systematic issues and prevent compliancegaps from becoming endemic
  6. Incident Planning

    • Know your roster of of Stake Holders
      • Info Security Team
        • Planning: Help identify vulns before bad actors exploit them. Also detection, isolation, removal and preservation of affected system
        • During Breach: forensic investigation, evidence preservation, deletion of malware, correcting vulns - often should bring in experts
      • Legal
        • Planning - seek experienced counsel vs internal teams - limit liability and eco impact. Read leg. NEgotiate reqs on biz partners
        • During a breach: Advising corporate of notification requirements to certain groups. Recommend sound evidence collection and preservation. Read contracts for reporting reqs.
      • HR
        • Planning: Employee data handling, security awareness training and incident recognition/response training
        • During a breach: updating employees. Helping with concerns. Help investigators. Work out consequenses.
      • Marketing
        • Incident Planning: Role due to how much data they handle
        • During Breach: Expert communicators, work with PR and management for messaging
      • Business Dev
        • Planning: manages vital biz relationships
        • Breach: Notify key accounts.
      • Communications and PR
        • During a breach: Front of line communicators. Message and accuracy
        • Planning: strategic programs to handle image and informatoin
      • Union Leadrship
        • Planning: Represent union intersets for employee data
        • Breach: Provide updates
      • Finance
        • Planning: cost effective measures to mitigate breach risk. Negotiate contracts with data breach resolution providers
        • Breach: budget parameters for a response to an event. Cyber insurance. Notification expenses.
      • CEO
        • Planning: Set tone for planning.. Personal accountability.
        • Breach: allocate funds/man power to resolve a breach. Publicly comment. Talk to authorities.
      • Customer Care
        • Breach: remain calm, escalate - internal or hire depending on org
        • Planning: Deploy tech to stop phishing/soclai engineering, employee training and awareness. Deter crim activity and breaches. Prep call center staff
  7. Incident Response and BCP Plan

    • BCP
      • Departmental responsibilities and actions before/after an event
      • Knowledge of the plan can make or brake an incident response
      • Tabletop exercise - simulation with a focus on familiarization of the plan. Conduct semi annually.
      • Updating the Plan - Add tabletop insights. Keep current. Update personnel as to changes.
      • Budgeting/training - long term costs outweigh benefits in good training of employees
        • Exposing gaps in applications, procedurs and plans in pre phase.
        • Greater overall security
        • Reduced financial liability and reg exposure
        • Lower breach related costs
        • Preservation of brand reputation and integrity in the market place
      • Breach response best practice -allocate sufficent funds.
    • Incident Detection
      • Privacy Definitions
        • Privacy Incident - potential or actual compromise of personal information -intentional or unintentional access by third parties. Incident/breach interchangeably.
      • Insiders/Third parties not hackers are the cause generally
        • Employee error or negligence is one of biggest causes of privacy breaches.
      • Encountering a Breach
        • Training should teach employees to recognize, report breaches.
        • Reporting Worksheets
      • Notification Requirements and Guidelines
        • Escalation - internal process of notification.
        • Notification - process of informing affected individulas
          • Mishandling can lead to fines and unbudgeted expenses
        • Immediately lock down internal communications and control
        • Confirm notification response timelines with legal counsel
    • Security is a Shared Responsibility
      • Ie HR and IT should work together to train and handle incidents
        • Hiring and promotion, layoffs and terminations - work with IT and Facilities
      • Physical Security
        • Facilities and IT should work together
      • Third Parties
        • Binding contractual obligations and reporting obligations
      • Tools of prevention
        • Pre- Notification Process -
          • Confirm event constitutes a reportable breach
          • Forensic Firms and Legal Counsel
            • Can deploy fast - chain of custody, document actions taken
            • Counsel handle legal obligations
        • Elements of a Privacy Incident Response Plan
          • Key Stakeholders - involved
            • Execution Timeline - should be in incident response plan
              • Progress Reporting - keeps everyone on track and informed
                • Response evaluation and modifications - breach is a strong teaching tool
                • Hourly - rare i.e. call center metrics immediately after
                  • Daily - for a few weeks - mail -senior management
                    • Weekly - investors and sakeholders
                      • Monthly - managers, stake holders, leaders and employees
              • Internal Announcements - send properly worded announcements to all employees
                • At same time as external statements
                • Employee only FAQs
                • Response Training for HR and call center
                • Explanatory letters
                • External Annoncements
                  • Closely coordinate with call center
                    • FAQ and training
                  • Staffing assesment for coverage
                  • Regulator Notifications
                    • Seek advice from legal
                    • Letter Drops
                      • + emails most common form of breach notification
                        • Check with law enforcement
                      • Call center
                        • Remediation Offers
                          • in letter i.e. credit monitoring
                        • Ensure adequate headcount and training
          • Developing an Incident Response Plan
            • Determine a Team Leader carefully.
              • Keep on track/objectives
              • Track budges for all response activities
              • Contact outside resources to confirm engagement and monitor resoureces
              • Prepare a final analysis of the response and post evaluation process
              • Response Team Members
                • Employees from all departments (including stakeholders) better to over communicate than neglect departments
                  • IT and IS
                    • Secure Transmission method for data files intended for print vendor or incident call center
                    • Find potentially compromised data
                    • No. of records breached and types of info
                    • Clean up mailing lists
                    • Sort through data to identify population requiring special handling
                    • Monitor for additional attacks
                    • Fix gaps in IT systems if applicable
                  • Legal - make decisions on:
                    • Notify regs and law enforcement
                    • Respond to media inquiris
                    • Alert credit agencies
                    • Negotiate contracts to mirror orgs commitments
                    • Manage evidence and investigation
                    • Review comms for liability
                  • HR
                    • Employee interviews internal/external
                    • Identifying indic who are in need of training
                    • Meetings to summarize updates
                    • Escalating concerns to dep heads
                    • Finance
                      • Setting aside and managing appropriate reserves
                      • Work with vendors to extend payment terms
                      • Pay invoices for breach related activities
                      • Meet daily to track incident expenses
                      • Request ongoing reports from breach providers to manage costs
                      • Marketing and PR
                        • Marketing practices to increase letter open rates
                        • Perform address hygine to improve delivery/response
                        • Analyze media and report developments
                        • Scripts for incident response call center
                        • Customer rentention campaigns
                        • Customer Care
                          • Handle aftermath/work with call center to estb service levels
                          • Outside Resources
                            • Use specialists
                            • Print Vendors
                              • Call center
                                • Remediation Providers

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Description
Privacy Program Managment Mind Map on Respond, created by Felicity Scott-Milligan on 27/07/2017.
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