Privacy Progam Metrics : Quantify
Akarsh Singh
Chief Privacy Officer @ Tsaaro Consulting | Consultant @ Data Privacy & Security
BUILDING METRICS FOR THE PRIVACY PROGRAM ?
What are privacy metrics?
The privacy metrics have emerged as key to measuring and enhancing privacy program performance and maturity in terms of customer trust, risk mitigation, and business enablement. Privacy leaders use metrics to benchmark the maturity of their organization's privacy program against its strategy and goals and demonstrate how privacy contributes to its plan and bottom line. They use metrics internally to secure budgets and staffing, measure performance and diagnose program status and needs, as well as externally to demonstrate accountability and enhance trust.?
Privacy Program:?
Privacy programs are organizational directions used to plan how an organization will protect its customer's and clients' personal information. These privacy programs?are often internal documents, unlike privacy policies, which are external documents of how an organization collects, processes, and uses data. A decent privacy program notifies employees how a company plans to keep information secure, who is responsible for managing the plan, and what actions will be taken during a security breach. Privacy programs are an integral part of the security program. The main aim of the privacy program is to maintain the confidentiality, integrity, and privacy of personal data and to avoid any damage or unwanted disclosures to PII.??
Significance:?
The best privacy leaders collect data and use metrics to measure, assess, and improve the performance of their privacy programs. It is said that 'measurement is management.' As famously summarised by Dr. H James Harrington, "What gets measured gets done. If you can't measure something, you can't understand it. If you can't understand it, you can't control it."?
Companies have a large amount of data for robust analytics, along with sophisticated reporting and management tools. If the metrics chosen by the organization misdirects the focus, the analysis can be erroneous.?Therefore, it is exceedingly critical to building appropriate and effective metrics to navigate the information optimally.?
Definition:?
The definition of privacy metrics as given in the 'Privacy Metrics Report' released by FPF?is that privacy metrics' are both quantitative and qualitative assessments that privacy leaders use to measure, manage, track, benchmark, report on, and improve their privacy program and its components and to establish transparency and trust; expressly, privacy teams may adopt the SMART Framework (Specific, Measurable, Actionable, Relevant and Time-Bound) to create SMART privacy metrics to assess their capabilities and fulfillment of objectives, demonstrating the relevancy of each metric while ensuring the completion of tasks within specified time frames.?
Purpose:?
Privacy programs use metrics for various purposes and goals, which can be categorized into legal, regulatory, and industry practice. By managing privacy programs, organisations can ensure that it complies with the corporate policies, standards, procedures, and applicable privacy and data protection laws and regulations. Legal and Regulatory Privacy Metrics includes measuring and tracking key metrics that demonstrate compliance with various laws and regulations. Industry practice includes measuring, documenting, and improving privacy programs. It also includes managing privacy risks.?
Categories Of Privacy Metrics:
1.Individual Rights
Privacy metrics includes Individual rights metrics which can be used to measure the rate of consent of data sharing and email marketing, data subject requests, customer satisfaction rates, etc. The individual rights metrics can help ascertain customers trust in privacy program and protect the customer's personal data.??
2.Training & Awareness
In Training and awareness metrics, the number of privacy trainings offered to staff and management is tracked. This helps improve the privacy knowledge of the organisation. By using the commercial metrics, an organisation can measure how many customers have signed data processing agreements.?
3.Accountability
Then comes Accountability metrics wherein organisation's projects can be tracked and based on the privacy and data protection impact assessment, privacy advice can be given and privacy policies and procedures can come into effect.?
4.Policy Stewardship
Then comes policy stewardship metrics which can turn data policies into common organisational practices and help in determining the scope of an organization's privacy products.?
5.Policy?
Policy metrics helps in gauging an organization's compliance with potential privacy legislation.??
Implementation of Privacy Metrics Program
In the context of privacy, a "metric" is the measurement of a specific activity that presents qualitative or quantitative characteristics about an organization's personal information holdings or an information-related process; a "metrics program" is the organized collection of a series of such measurements.?
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Evidence:?
Privacy metrics provide evidence of compliance with legislative/regulatory requirements and internal privacy policies and procedures. They are helpful in boards to enhance organisational governance and support management in making privacy-related decisions.?
Stages of Implementing a privacy metrics program: ?
●??????Metrics Development. Defining privacy metrics, including benchmarks.?
●??????Information Collection. Identifying or confirming data sources and ensuring that they are accurate and consistent.?
●??????Report Development. Developing procedures to record and analyse the metric information, providing suitable formats for detailed and summary reports.?
●??????Implementation. Adopting the procedures and reporting requirements.?
Determining Privacy Metrics:
Benchmark:?
If there is a "high" benchmark, a "low" number in the early periods of information collection may not reflect a "bad" metric. This indicates the need to re-adjust the benchmark to what, over time, is recognised as the historical norm. Sometimes, there may be no benchmark or desire to have a benchmark. Carefully consider how you will build a metrics report. Think about the difficulty in sourcing the information to populate your metrics report. Also, think about reporting in terms of "frequency", "collection", and "reporting". "Frequency" reflects the period through which the metric is measured, e.g., monthly, quarterly, or annually. "Collection" may vary from "reporting" because metrics may be collected monthly for privacy management purposes but compiled quarterly into senior management reports.?
Monitoring & Reporting:?
Then monitor your privacy metrics program and assess the relative maturity of the metrics. You may find that, over time, one or more metrics may "fall away" in importance because of the "smooth running" of that activity. Revise your privacy metrics program as appropriate. Whatever metrics you choose, don't advertise them. Why? Think about the observer effect, where people change their behaviour when aware of being watched. Publishing the metrics makes employees more aware of their actions and, invariably, will begin to influence reporting.?
Breach Notification:?
Lastly, A common adage in business should cover privacy in an age of data breach notification "you can't manage what you don't measure should cover privacy in an age of data breach notification re". Performance measurement is considered an essential component of business management and, in an age of data breach notification, should cover privacy. Privacy metrics provide the critical performance indicators for measuring measurement of your organisation's privacy performance.?
Conclusion: ?
Privacy programs are important because they can help organisations?maintain privacy,?prevent data breaches , maintain data governance and comply with regulations. This article briefly describes the definition, significance, categories, and implementation of privacy metrics.?Privacy issues can?no longer be ignored by an organisation. It becomes significantly vital to get an organisation's priority set on securing privacy. Privacy metrics can be an effective way of evaluating the strategic value of privacy initiatives. The utilization of privacy metrics can help organizations accomplish many objectives, including benchmarking against industry standards, ensuring compliance with privacy laws and regulations, increasing customer trust, and asserting the value of existing privacy programs.
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2 年I seriously believe that Privacy is still facing the issue of abstraction at large. As it comes to Privacy metrics, the issues are primarily twin fold. One has to identify Strategic metrics which link to the business objectives, then the challenge arises that how will you quantify those metrics. I would like to understand how do you measure individual rights, from where one would source the data?
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2 年Piyush Koshe