Information governance programs and privacy programs share many common components, goals, and people. Many organizations find that integrating data protection and information management and coordinating these two initiatives, despite relatively different goals, can minimize duplication on both sides and improve effectiveness for both. Let's take a look at some of the similarities and examine how privacy and IG can help each other.
The requirements for information governance and data protection are very similar, although they are not identical. Both start with policies and procedures – essentially the basic mode of the programs and how they work on a daily basis. In addition, Information Governance requires a Record Retention Plan – a policy document that defines an organization's legal compliance and record keeping requirements. Information management roles are also required that are counterparts to data protection roles in data protection programs. Both of them have to deal with legal reviews, and both create data cards to perform these reviews, although these data cards look different.
Information governance and data protection governance are also fundamentally very similar. Both require an alignment to the users of the given program and certain procedures in that direction. By integrating the two, an organization can ensure that both its users and its own business interests are protected from bad actors and legal ramifications on all sides. A solid privacy and information management policy serves as the foundation for corporate governance and is supported by detailed and clear procedures for certain everyday and infrequent situations such as opt-in / opt-out privacy policies or standards for information distribution.
Of course, all of these policies and procedures also need to be brought into practice with a variety of data protection laws from the various countries in which your organization operates.
A clear structure of command and a system of accountability are essential for both information management and data protection programs. Chief Information Officers (CIOs) and Chief Privacy Officers (CPOs) manage the entire department and are considered to be responsible for the departments. Records Managers and Analysts ensure that records are securely managed and secured on a broad policy basis, and records stewards ensure that the daily use of records is safe. Likewise, on the data protection page there should be data protection analysts and stewards who work to ensure compliance with data protection regulations in all its nuances.
These groups must also work with other parts of the organization. namely, legal teams who ensure the organization complies with data protection and records management laws, senior executives who deal with strategic management and coordination within the organization, ethics and Risk Compliance Experts who assist the company in addressing ethical issues related to data protection, and Information technology actors who may be responsible for ensuring that electronic records, especially those with data protection concerns, are effective and stored securely Maintaining reasonable accessibility.
Internal audits of records and data protection departments can be extremely helpful in identifying internal vulnerabilities before they become a problem. By quickly identifying these vulnerabilities, losses and breaches of security and privacy can be avoided before they occur.
Information governance audits take place in several steps. The first is to identify the context of the exam. This is your “measuring stick” – this is where you define the standards and type of audit as well as the guidelines and methods that you are reviewing. Then carries out the audit itself to determine whether the current methods comply with the standard required by the organization. Then the reviewers must analyze the results identifying the strengths and weaknesses of the current information governance program and determining where the policies need to be changed within the program. The auditors then develop a set of mitigation strategies and provide recommendations for their implementation to ensure that new policies are introduced smoothly and with minimal risk to the organization and those affected by the changes.
By combining the audits, a more efficient and comprehensive audit can be created, thereby reducing the cost and efficiency impact of both. The results can then be reported together, with separate issues highlighted, so that mitigation strategies can stay closely aligned.
Data mapping is a method of determining the risk to customers and parts of your business by identifying the flow of information, the storage of information and all points at which it is accessed. In this way, an organization can efficiently identify areas in which data protection or information security could be breached and develop new strategies to mitigate these risks. A comprehensive data card could contain:
Training related to audits, information management and data protection must be continuous and emphasized for a good policy to work. Of course, when people are not informed about the how and why of politics, it weakens and can be more easily exploited by bad actors. Annual training courses should also be created so that updates to information and privacy policies can be easily disseminated across the company. This content can also be incorporated into other training methods of the organization, especially those that were recently or originally involved in the organization.
In order for information management and privacy policies to work, they must be an integral part of the corporate culture from the ground up, and must be both continuous and adaptable to the needs of the organization and those who do it. The two programs benefit greatly from being integrated with one another to compensate for the weaknesses of both parts and to expedite the examination of their weaknesses. Properly managing these two parts can greatly minimize and reduce the organization's legal, financial, and informational risks.
For more information on the integration of data protection and information governance, see this webinar recording: Webcast: Integrating data protection into your IG program