Change Doesn’t Happen All at Once: Navigating the GDPR Transformation Process
Here we are at the beginning of 2018. And with the start of a new year, we often find ourselves thinking about making changes both big and small. So it seems especially fitting to turn our attention to the Transform phase of the IBM Security General Data Protection Regulation (GDPR) framework.
The goal here is to reach at least a minimum level of readiness before GDPR comes into effect on May 25, 2018. Ideally, that would include being ready to produce a privacy risk impact assessment. That’s one of the first items a regulator is likely to want to see — along with the assurance that you have validated processes and activities in place to sustain or refresh its status.
A secondary goal would be to demonstrate your readiness to address the GDPR Article 30 requirement for records of processing. To do so, you would need to at least be able to provide a summary inventory or catalog of the personal data that’s relevant to your business — including information about where it’s stored and processed and its lineage.
In our two most recent blog posts, we discussed the process of deciding what you need to do and how you can do it. You’ve made some of the important decisions and it’s likely you’ve developed a plan. Now you should be ready to start implementing that plan. Note that I used the word “start.” That’s because the Transform phase is all about beginning to make your transformation toward GDPR readiness. It’s a slow and controlled rollout that allows you to take an incremental approach to making the changes you’ve deemed necessary.
Clearly, it’s not time to flip the switch just yet. But it is a good time to recognize that there may be problems. In fact, that’s the reason the Transform phase is one of the key elements of the framework. It gives you an opportunity to tease out the problems and determine what works and what doesn’t — in a controlled environment. Think of it as a road test on a closed track where your mistakes can be easily detected and aren’t likely to result in catastrophes.
Where to Begin?
In terms of GDPR privacy requirements, this is where you begin to implement and execute policies, processes and technologies, including those related to data subject access requests. And to meet GDPR security requirements, you should be starting to implement privacy-enhancing controls such as encryption, tokenization and dynamic masking.
You should also consider implementing required security controls, including access control, activity monitoring and alerting. In addition, you may need to mitigate any access risks and security vulnerabilities that you discover.
What Exactly Will You Be Transforming?
If you’ve already worked through the Assess and Design phases of the framework (which is likely at this point), you should have the answer. During those two phases, you would have identified your targets, decided your metrics, focused your team and agreed on a plan — because it will take a united effort to move forward.
Now is the time to start rolling out your new processes and procedures for meeting the GDPR privacy requirements. Start with a few and see what works for your organization.
At the same time, you can start rolling out your security-enhancing controls. Test them with a pilot team and determine what’s useful. And keep in mind that these may be major changes for some parts of your organization, which makes it your job to see that the transition to new policies and procedures goes as smoothly as possible.
How to Succeed
Frustration can come easily when you’re making a lot of significant changes to the way things are done. And while there isn’t any single right way to navigate the Transform phase, consider what I view as best practices to help you avoid unnecessary conflict at this point. Here’s a list of the most important ones:
- Pay attention to your stakeholders. They’re the ones in the best position to spot problems and propose workable solutions.
- Start with a solid project plan. That can help you identify potential issues and pitfalls before they impact the entire process.
- Station a good team on the ground. They should be able to both see the big picture and know when to zoom in on the details.
- Insist on active participants. You need a team of doers who are ready and eager to both do the work and communicate constantly.
- Cultivate executive leadership support. It’s good to have the C-suite on your side when you to need to make some tough decisions.
- Set expectations. You know this is going to be a slow process and that things may go wrong; make sure everyone else knows it, too.
- Communicate your vision early on. Be clear about what you want to see happen and about how you’ll define success.
So, yes, GDPR requires making a lot of changes. And, as you’ve likely figured out, some of those changes can be pretty complicated. But as we’ve been saying for some time now, with a clear understanding of what you need to do and a plan for doing it, you can resolve to make those changes happen.
Notice: Clients are responsible for ensuring their own compliance with various laws and regulations, including GDPR. IBM does not provide legal advice and does not represent or warrant that its services or products will ensure that clients are in compliance with any law or regulation. Learn more about IBM’s own GDPR readiness journey and our GDPR capabilities and offerings to support your compliance journey here.