Privacy Risk: Ask This;
Gerard Blokdyk
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Privacy Risk: Ask This;
TLDR: Ask This;
1. How does your organization identify, assess, and mitigate data security and privacy risks associated with AI?
2. Does your privacy notice account for to data subjects what information about them will be shared?
3. Do you have the appropriate leadership, structure, capabilities, resources, collaboration, and support to manage data privacy risks in the context of your business model and goals?
4. How do consumers perceive privacy risks when presented with information about the nature of smart grid data collection and use?
5. What new privacy risks have been introduced to your data now that cloud services are being used?
6. What is the privacy risk to the information asset how easily could the confidentiality of the data subject be breached?
7. Does your organization have a process in place that captures and assesses all privacy related incidents and data breaches?
8. How significant are the privacy risks posed by unindexed data backups and other latent information about individuals?
9. Does your organization have a governing body in place to address the acceptable level of privacy risk it will take?
10. What is the perception among users of potential security and privacy risks associated with using cloud data storage solutions?
11. Does the receiving party have comparable privacy and data security obligations in place?
12. Do your board and senior management consider privacy and data protection risk an important part of strategy to grow your organization?
13. How do you reduce the privacy risks related to re using the data for other purposes?
14. Can the information systems implement the security and process requirements needed for Privacy compliance?
15. How have security and privacy risks increased with the deployment of connected devices?
16. Does your organization currently take account of privacy risks in the context of its overall risk and/or project management process?
17. Do you have a formal process in place to assess the privacy risks in corporate initiatives?
18. How to maintain the fine balance of data privacy risk versus increasing demand to access the data?
19. Can emerging privacy enhancing technologies mitigate privacy risks to individuals while preserving the benefits of robust aggregate data sets?
20. How do perceived privacy risk and perceive benefits affect information protection attitudes?
21. What are the privacy risks and / or open records consequences of the information and / or service involved?
22. How do you assess the risk presented by your external third parties to privacy and data protection expectations?
23. Are you considering privacy risks to individuals before designing your information systems, business practices and physical design?
24. What are the risks associated with becoming connected, including the potential cyber and data privacy risks?
25. Do you protect privacy by ensuring that data destruction complies with your risk strategy?
26. Does your organization have a process in place to identify and mitigate privacy risk?
27. Has identifying and assessing security and privacy risks been incorporated into the overall risk management planning?
28. How is a privacy risk level of corresponding networking data determined and differentiated?
29. Does your organization currently consider privacy risks in the context of your overall risk management process?
30. How much intellectual property and privacy risk does your organization handle before it needs to find alternative methods of financing the risk?
31. How do you develop a modern privacy risk index for official data releases?
32. Does your organizations IT strategy include an incident response plan that is evaluated regularly to ensure it addresses new and emerging types of security and privacy risks and breaches?
33. How should organizations manage people, embed processes and harness technology to increase transparency and mitigate data privacy risk?
34. Which information security and privacy threats are of most concern to your organization?
35. How is your organization addressing IoT specific privacy risks in terms of each risk consideration?
36. What are the objectives in assessing privacy risk in a transitive health information workflow?
37. Does your organization have any mechanisms in place to detect when privacy breaches occur?
38. How will you identify and retrieve all information in a system that relates to a data subject?
39. Is there a tool that could help identify which type of privacy risks need to be considered in IoT system design?
40. Do you have validation and sign off strategy for privacy risk mitigation and acceptance by the compliance team?
41. Do you protect personal privacy by controlling how data elements are disclosed and transmitted?
42. Is training given to all staff on good data protection and information security practices?
43. Does the group represent people whose data is being collected and used and whose privacy at risk?
44. Do you protect privacy by ensuring that data destruction complies with privacy principles?
45. Do you protect privacy by controlling how data elements are accessed for destruction?
46. Does your organization have responsibility and accountability assigned for managing a privacy program?
47. How do you manage security and privacy risks and requirements in Agile software projects?
48. Who has approved the privacy risks involved in the project and what solutions need to be implemented?
Organized by Key Themes: DATA, PRIVACY, RISK, SECURITY, COMPLIANCE, MANAGEMENT, DIGITAL, TECHNOLOGY, LEGAL, DEVELOPMENT:
DATA:
Have there been any incidents of negative feedback from the public regarding privacy?
Develop and coordinate an organization-wide privacy risk management and compliance framework and governance structure by undertaking a comprehensive review of your organizations data and privacy process and procedures for each applicable business function to ensure that they are consistent with relevant laws and regulations and your organizations privacy and data security goals and policies.?
What auditing measures and technical safeguards are in place to prevent misuse of data?
Certify your organization is interacting with internal privacy program managers, product development teams, legal, compliance, governance and data protection teams to analyze, design and program software enhancements for new data streams with a goal of developing technical solutions and systems to help mitigate privacy vulnerabilities and prevent potential future privacy risks.?
Who responds to potential security issues and ensures that security patches are tested and applied?
Secure that your process maintains and enhances the privacy program, including appropriate policies and procedures, to enable consistent, effective data privacy practices, minimizes privacy risk and ensures the confidentiality of private (internal) client and team member data.?
Are you considering privacy risks to individuals before designing your information systems, business practices and physical design?
Assure your group is conducting privacy risk and compliance assessments inclusive of regulatory requirements and leading data protection practices.?
Does the data controller plan to implement new technologies for the considered process?
Coordinates with stakeholders across the enterprise to develop and implement data privacy risk management plans.?
What steps have you taken to identify the data processing activities of your organization?
Make headway so that your strategy performs privacy risk assessments to identify potential risks, as well as gaps in data protection compliance.?
Who has approved the privacy risks involved in the project and what solutions need to be implemented?
Collaborate with IT and other relevant business functions to validate and mitigate any data privacy concerns for third-party due diligence assessments, for which privacy and compliance considerations are involved.?
Are evaluation requirements, including requirements regarding the type and frequency of self assessments, audits, tests, and/or metrics collection documented, approved and effectively implemented?
Serve as a conduit and business point of contact to collect questions and needs from cross functional stakeholder groups regarding data privacy compliance requirements and requisite activities.?
How can privacy risk be modeled to support privacy risk identification and management?
Provide privacy related guidance and support for the business and corporate functions for inquiries, incidents, and privacy risk/impact assessments, including Data Protection Impact Assessments.?
Is there an Incident Reporting and Incident Handling process that meets the needs of the customer?
Define and facilitate the data privacy risk assessment process, including the reporting and oversight of treatment efforts to address findings.?
PRIVACY:
Do you have any concerns with how the third party applications handle the privacy of your data?
Make sure your design oversees and coordinates privacy and information security compliance program activities, including privacy risk assessments, vendor due diligence and data management and protection.?
Does risk management have the demonstrated support and ongoing attention of executive management?
Work with cross-functional business teams, including Legal, Engineering, People Team (HR), Finance, and Security to address potential compliance issues and achieve data privacy program initiatives and provide as-needed support to leaders and stakeholders across your organization.?
Are evaluated risks reviewed by an independent person to ensure risks are treated consistently?
Conduct privacy impact assessments and counsel the business regarding privacy and data protection compliance and other applicable risks with respect to use of vendors during the risk review process.?
Does your notice of privacy practices inform clients of health information privacy rights?
Collaborate with IT Risk, Information Security, and Data Management to ensure alignment between security and privacy compliance programs, including policies, practices, incident response, and investigations.?
Is a process for identifying, reporting, tracking, and monitoring all issues to resolution in place?
Check that your team oversees routine data sharing with third parties, performs risk assessments and develops work plans to manage critical risks, maintains effective privacy policies, and assists leadership in implementing strategic privacy initiatives and reporting on all elements of the system privacy program.?
Did your organization provide appropriate training to support its social media policies?
Make sure your design is involved in counseling on business process support for privacy and cybersecurity programs (website and mobile app audits, risk assessments, policies and procedures).?
Has your organization determined appropriate risk criteria that align with its objectives?
Make sure your process is involved in developing risk management strategies related to privacy risk arising from data processing activities.?
How do you promote a risk-aware culture in your organization?
Stay abreast of new privacy and data protection requirements and assess their impact on existing technology related products, services and operations; modify policies and procedures accordingly and collaborate with business teams to promote alignment between requirements and policies and procedures.?
What standards and controls are you using to protect the data from inadvertent or intentional disclosure of protected information?
Invest in implementation and management of a data privacy framework to support role-based user access and routine data sharing with business partners, affiliates, and third-party clinicians, and others with whom protected health information is shared.?
Has your organization Covered Entity Status based on the Privacy Regulation been determined for each entity?
Oversee that your workforce is complying with and understanding reputational risk mitigation, emphasizing you and international Privacy, Data Protection and Information laws and understanding the privacy risks impacting a particular industry;.?
RISK:
Is control design and implementation responsive to changes and growth in your organization?
Drive identification of emerging data privacy risks and implementation of appropriate controls, including conducting Privacy Impact Assessments, for all new and changed products, processes, projects and partnerships and ensure implementation of mitigating controls in partnership with business team leads.?
Does your personnel understand role in handling and protecting personal data and the consequences for violations?
Assure your strategy is collaborating across the Enterprise Privacy team, lead in the development and implementation of monitoring and testing coverage plans, privacy risk assessments, business process assessments, and privacy reviews for third parties handling personal information.?
How can privacy risk be modeled to support privacy risk identification and management?
Review and assess privacy related risk with business partners to identify and address privacy related compliance gaps or areas of privacy risk in support of business requirements.?
How do you go about identifying unauthorized user behavior or detecting data exfiltration?
Check that your staff is partnering with business units to develop a roadmap of programs designed to mitigate privacy risks and promoting a privacy and data protection mindset.?
How many audit committees are actively involved in succession planning with the CFO office and internal audit?
Warrant that your company is involved in compliance operations/strategy, privacy risk assessments, common controls frameworks, privacy maturity assessments, and process design/mapping related activities.?
What policies and practices will you need to adapt or create to best address privacy, security and confidentiality issues on different social networks and media sites?
Lead data protection technical impact assessments to identify and manage data privacy risks and data classification needs arising from new projects and existing systems and processes, in accordance with the established policies; ensure data processed and stored by IT systems and applications is aligned with local international data protection and privacy requirements and best practices.?
Do you have the appropriate leadership, structure, capabilities, resources, collaboration, and support to manage data privacy risks in the context of your business model and goals?
Safeguard that your company supports the integration of privacy risk management processes into the RMF to better support the (internal) clients privacy protection needs.?
What do you do to minimize the damages of physical, technical and/or security incidents?
Make sure your design evaluates data privacy risks, performs data privacy impact assessments, and supports the development and implementation of solutions to minimize those risks.?
Do controls comply with policy requirements, legal obligations and entity procedures?
Secure that your operation is evaluating business line initiatives and processes from a privacy risk perspective.?
What are the privacy risks and / or open records consequences of the information and / or service involved?
Safeguard that your team is involved in privacy impact assessments as well as privacy risk remediation efforts.?
SECURITY:
Is there an Incident Reporting and Incident Handling process that meets the needs of the customer?
Secure that your strategy performs information security and privacy risk analysis to provide expert cybersecurity guidance to support cybersecurity program development, coordination and execution, outreach, and reporting on program effectiveness.?
Is there a privacy risk in accessing or monitoring employees personal social media accounts?
Make sure the l Information System Security Officer (ISSO) supports all Risk Management Framework (RMF) activities including the process managing security and privacy risk, including information system categorization; control selection, implementation, and assessment; system and common control authorizations; and continuous monitoring.?
Does your organization have the necessary policies and procedures in place to support risk management?
Liaison so that your workforce oversees the operational day-to-day activities intended to mitigate Information Security and Privacy risks at the technical level, including monitoring, vulnerability scanning and management, incident response, security engineering, and business continuity management support.?
Is there a privacy risk in accessing or monitoring employees personal social media accounts?
Warrant that your company performs initial and periodic information security and privacy risk assessments and conducts related ongoing compliance monitoring activities.?
How do you expect your personal information to be best protected?
Make sure the CRP Privacy and Information Security Analyst II performs risk assessments and reviews to identify key corporate information security and privacy risks that affect the confidentiality, integrity and availability of electronic protected health information and other company confidential data.?
Are individuals notified of the purposes of collecting, using or disclosing of the personal data?
Carry out activities at the organization, mission, business process, and information system levels of the enterprise to help prepare the (internal) customer to manage its security and privacy risks using the RMF.?
What privacy risks did your organization identify regarding the amount and type of information to be collected?
Conduct security and privacy risk assessments to identify areas of unexpected risk to business and technology operations.?
Have appropriate privacy risk assessment tools been identified or developed to assist in assessing the privacy risks of cloud services?
Invest in identifying and assessing your organizations key information technology, security, and data privacy risk areas.?
How do people negotiate privacy risks when selecting or allowing privacy permissions, and do choices vary in different contexts?
Certify your workforce is advising area leadership on the development and execution of the Security and Privacy Risk service line growth program and overall go to market strategy.?
What affects the immediate working environment in which the identity service operates?
Establish that your staff manages threat, vulnerability, and security and privacy risk (including supply chain risk) information for organizational systems and the environments in which the systems operate.?
COMPLIANCE:
Is a process for identifying, reporting, tracking, and monitoring all issues to resolution in place?
Work with the Data Security Governance, Compliance, Trust and Safety and InfoSec teams to scope and perform periodic data privacy risk assessments, mitigation and remediation, including data control design and monitoring, and the mitigation of privacy and security risks.?
领英推荐
Are there policies or guidelines in place with regard to the retention and destruction of PII?
Establish that your operation follows written risk and compliance policies and procedures for business activities.?
Does your organization have any mechanisms in place to detect when privacy breaches occur?
Participate in the development and implementation of the enterprises risk strategy for effective risk and compliance program governance; intended to strategically and proactively mitigate risk, and promptly detect and correct instances of non-compliance.?
Will the project or system involve the collection of new information about individuals?
Develop experience advising business partners on data protection compliance issues.?
How do your organizations IT auditors establish the completeness or veracity of the source data?
Matrixed working relationship with Risk Operations and Strategic Risk Partner to define the development, implementation and maintenance of an effective compliance and risk management program for the supported entities.?
What are the current difficulties in implementing cybersecurity practices into your business?
Help translate control deficiencies into action plans and provide consultation on the design of controls to enhance governance practices with risk and compliance frameworks.?
How to prevent unwanted information leakage, data exploitation, and information linkage?
Help develop an internal controls program to identify and prevent compliance risks which steam from all areas of business activities.?
Will the project involve the matching or combination of datasets from different sources?
Assure your process leads and participates in considerations or presentations to existing Compliance or Risk Committees and the Audit and Compliance Committee meetings of the Board.?
How to maintain the fine balance of data privacy risk versus increasing demand to access the data?
Build and maintain the enterprises information Governance, Risk and Compliance (GRC) program.?
Do appropriate administrative procedures, policies and procedures exist that effectively manage privacy risks with cloud based services?
Monitor changing industry and legal standards to ensure Compliance policies remain current, and that the business is executing effectively to those standards.?
MANAGEMENT:
Do you foresee that the GDPR related engagements will become recurring audits in your audit plan?
Manage the development of operational risk policies and procedures, governance framework, risk assessment, risk screening and risk mitigation, produce gap analyses, business process analyses and strategic process improvement, provide change management leadership, develop comprehensive internal audit plans including clear scope, objectives, and milestones to evaluate efficiency and effectiveness of the control infrastructure and to strengthen process, system, and governance controls and frameworks.?
Where an employees biometric data is collected as part of surveillance, are employees notified beforehand that surveillance can occur and/or is general policy?
Check that your organization uses an integrated risk management approach to create perspectives and status reports regarding all security/privacy risks the organization may encounter including risks in physical security, access and control issues, data security and contingency planning.?
Can policies and procedures prepared for compliance with other regulations substitute for the plan?
Perform privacy reviews, identify gaps in privacy architecture, and develop a privacy risk management plan.?
How are technology and personal information improving learning for individual employees?
Assure your design is involved in Security Vulnerability management, data protection and the ability in understanding and translating security policies into information security solutions.?
Are risks treated in accordance with the pre determined risk criteria established by your organization?
Provide audit response management and ongoing guidance on solutions to achieve and maintain security compliance, to mitigate information security risks and to correct compliance exposures and gaps.?
Are your customers/clients/employees properly informed about metadata that you collect?
Advise procurement and information security functions on the vendor risk management process and issues.?
Is there a nominated data controller or equivalent who is accountable for protecting biometric data collected?
Oversee that your strategy is promoting a culture of risk management by building relationships and creating awareness about the risks facing your business partners and your organization.?
Is a process for identifying, reporting, tracking, and monitoring all issues to resolution in place?
Set priorities and manage the Cyber Analytics, Risks and Automation function, including strategy and product management data management and insights (people, process, technology), automation development and support, as well as reporting and analytics.?
Is training given to all staff on good data protection and information security practices?
Build a strong partnership with your Risk and Compliance and Internal Audit teams for the design and effectiveness of how Procurement supports your supplier management practices.?
Does the business have strong information management, security, retention and destruction processes and policies?
Be sure your team is involved in guiding your organization to enhance business processes of integrating case and performance management systems.?
DIGITAL:
Do staff in your organization know what inappropriate management of personal information is?
Make sure your strategy collaborates with Marketing and Digital Health leaders to identify and manage privacy risk in products and services.?
Does the initial risk assessment or screening process consider mitigations and residual risk?
Warrant that your workforce develops and manages budget and business plans for (internal) customer digital and technology team.?
Do you need to make a restricted transfer of personal data in order to meet your purposes?
Partner with IT and OT to develop proposed digital solutions to meet key business needs.?
How do you conduct a privacy risk assessment?
Build and develop a high performing team to aid in the development and execution of digital initiatives.?
How will you identify and retrieve all information in a system that relates to a data subject?
Be sure your team contributes industry and (internal) customer insights to inform digital transformation account planning.?
Who has approved the privacy risks involved in the project and what solutions need to be implemented?
Secure that your workforce is involved in digital innovation and roadmapping projects.?
How long did the client spend selecting the product, compared to your typical client?
Perform effective vendor management for outsourced digital channel partners.?
Do you have the appropriate leadership, structure, capabilities, resources, collaboration, and support to manage data privacy risks in the context of your business model and goals?
Lead Digital (internal) customer journey design across the enterprise.?
What possible control measures or solutions should be considered for confronting BYOD policy from risks, threats, vulnerability and attacks to information security and privacy?
Develop and maintain metrics to effectively measure the impact of digital transformation journey.?
Are there any risks presented by the physical environment or location of the activity?
Make sure your workforce oversees digital channel vendor management.?
TECHNOLOGY:
Have you conducted a privacy risk assessment to identify potential harmful impacts to end users and identify mitigating controls?
Collaborate with technology and process engineering teams to design best in class (internal) customer experiences while mitigating privacy risks.?
Do you need to make a restricted transfer of personal data in order to meet your purposes?
Secure that your staff provides recommendations to leadership team on new technology solutions to meet business objectives.?
What are you doing to help organizations mitigate risks from social media, or collaboration apps?
Ensure your team works closely with your Business Development team to help with (internal) client technology and questions.?
How will the technology used or developed enable or support each step in the business process?
Identify any product/functionality gaps and collaborate internal product and technology teams to define the necessary development to support solution delivery.?
How much harm could be done if consumers personal information is stolen because of RFID?
Scan environment for technology or business model changes that could impact the business.?
How can compliance costs for organizations be kept in proportion to the privacy risks?
Make sure your personnel has involvement driving information technology improvement projects with results showing evidence of improved efficiency and cost savings.?
Is message content retained by the app organization after a message has been delivered?
Ensure your goal is to deliver technology that is centered around your business and your collective success.?
Does the asset involve new or changed data access or disclosure arrangements that may be unclear?
Be certain that your team is learning and Development Leader, Technology.?
Which contracts require vendors to process personal data on behalf of your organization?
Act as a liaison to the information technology department.?
Is any personal information collected by your organization disclosed to third parties?
Engage with relevant peer, technology and analytics teams to develop templates and documentation related to evaluating new internal tools, features and functionalities.?
LEGAL:
Does your organization have a process in place that captures and assesses all privacy related incidents and data breaches?
Support and develop policies and internal controls working with legal teams and business owners to ensure your organization is complying with regulatory obligations on an annual basis as it relates to Third Party integrations.?
How is data protected in transit to ensure that only the intended recipient can access it?
Work with all organization personnel involved with any aspect of release of protected information to ensure coordination with your organizations policies, procedures and legal requirements.?
Do processes and systems that allow users to access own personal data include metadata?
Ensure your organization is involved in programs that include legal and engineering requirements.?
How do you measure and quantify privacy?
Interface so that your organization handles sensitive information that is proprietary, privileged, confidential or otherwise legally exempt from disclosure.?
Is there a privacy risk in accessing or monitoring employees personal social media accounts?
Develop regulatory and legal strategy with processes and monitoring systems.?
Is it necessary to assign or collect a unique identifier to individuals to enable your organization to carry out the program?
Enable translation of legal requirements into procedures and action plans that are consistent with the needs of the BU.?
How do you use your information?
Liaison so that your process drives results across the legal department.?
How are you ensuring that personal data obtained from individuals or other organizations is accurate?
Verify that your company contracts specialization Paralegal.?
Should your organization be able to charge the third party or individual for providing the data?
Convey complex legal concepts and requirements to engineering in ways that resonate with them.?
Are you relying exclusively on consent in order to process information of individuals?
Support legal department in drafting, negotiating, and executing contracts and other agreements with third parties.?
DEVELOPMENT:
What tools are available to manage privacy risks to help the parties complete a transaction?
Ensure you work closely with development on the specifications to ensure the Agile team has all of the information you need to deliver a complete product to market.?
How do you record and report personal data breaches?
Invest in development of action plans for issues/gaps identified during reviews and work with business stakeholders to determine appropriate monitoring and testing routines.?
Will training be required, and, if so, when should it occur in relationship to project deliverables?
Lead development teams through a matrix managed structure to deliver analytics products and other tools in alignment with business requirements and objectives.?
Do you have the appropriate leadership, structure, capabilities, resources, collaboration, and support to manage data privacy risks in the context of your business model and goals?
Develop and maintain product roadmaps and strategies, manage business and technical requirement gathering and product prototyping, and lead development and delivery of relevant training.?
Do technical controls and processes adequately support social media policies and standards?
Lead key Business Development projects in support of corporate objectives and timelines.?
Do you use procedures to control how ecosystem roles and responsibilities are carried out?
Warrant that your workforce supports team to establish and maintain relationships across disciplines to build common tools, language, systems and structure to drive development of team.?
Who has approved the privacy risks involved in the project and what solutions need to be implemented?
Liaison so that your operation is involved in business development, proposal drafting, and marketing of professional services.?
Should organizations have an ethical obligation to manage consumers personal information in line with best practice and expectations?
Manage the development and execution of Information Governance team members.?
How do consumers perceive privacy risks when presented with information about the nature of smart grid data collection and use?
Consult on the development of business requirements for new system implementations and enhancements.?
Who in the IT organization is responsible for keeping executive management and the board updated regarding your organizations information security and privacy risks?
Be certain that your team is responsible for managing the development and implementation of all budgetary and financial policies and processes.
Enterprise Architect
2 年Thanks for posting
Enterprise Architect
2 年Excellent Article