As cyber security risks increase and new data protection requirements surface, navigating the privacy and security landscape has become ever more onerous and demanding.Even in organisations with well-established and mature enterprise risk management programs, keeping your risk picture updated and actually having your identified risks under control have become an arms-race.
Below, I will share a few risk-reducing steps that will put you in the driver’s seat, and allow you to take back some control of your privacy and security risk management activities in 2023
Conduct risk assessments:
Well, not exactly a surprise considering the topic of this post, but here I am not only thinking about specific DPIAs or a function- or site-specific security assessment. Look ahead and look at the broader picture. Identify broader potential organisational risks, assess their root cause, and evaluate their likelihood and impact. This will help you be proactive in your risk management and take appropriate measures to address them. And make sure to establish a strong connection between the Security and Privacy functions in your organisation. Often security risks will materialise as data breaches. And data protection risks may require your organisation to implement specific security measures. If privacy and security risk assessments happen in silos, you are not managing your risks effectively.
Implement risk management procedures with a wider scope than mere legal compliance:
Establish policies and procedures for identifying, mitigating, and managing risks, that are broader than the specific requirements that may originate from legal requirements. This includes setting up systems for reporting and tracking risks and implementing controls to prevent or mitigate identified risks. While DPIAs and specific security assessments will typically relate to a specific event, service or processing activity. The scope for the proactive and broader risk management should be event agnostic and take place as a recurring forward-looking assessment of risks.
Use technology to effectively manage and mitigate risk:
Implementing technology solutions such as cybersecurity measures, privacy management platforms with effective risk management built in, recovery systems, and whatever technical measures or tools which may be relevant, can significantly help you reducing the risk of data breaches, data loss, hacking etc. These systems and tools need not be expensive (compared to the cost of a data breach ;-), but they can provide a vivid boost to your risk management capabilities.
Develop contingency plans:
Things will go wrong, you will be hacked, you will experience data breaches. So, create contingency plans before it is too late. It will help you prepare for and manage (un-)expected events. Have a playbook ready for when the proverbial hits the fan outlining courses of action, relevant internal and external stakeholders to involve, and establishes the necessary procedures for communication and decision-making for crisis-management. And, run internal fire-drills – at least on a yearly basis – to test your plan.
Foster a culture of risk awareness:
Encourage your colleagues to be proactive in identifying and reporting risks. It will help you in your work of identifying risks that would otherwise have been unknown to you. Get your managements buy-in and have them support you in promoting a culture of risk awareness and management throughout the organisation.
Regularly review and update your risks:
As mentioned in the beginning of this post, the privacy and security landscapes are constantly changing. Hence, perform regularly reviews of your risk management efforts. This will allow you to ensure that they are still relevant and effective in identifying and mitigating your organisations risks.