Emergency Compliance DG Special Case DAMA INDIANA
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1 1 Emergency Compliance DG Special Case DAMA INDIANA
2 Agenda 2 Overview of full-blown data governance (DG) program Emergency compliance with a specific regulation We'll use GDPR as an example What is GDPR and what needs to be demonstrated GDPR profoundly affects marketing Streamlining DG for GDPR You may be able to leverage some existing tools Starter kit items Links GDPR Glossary
3 What is Data Governance? 3 DG is a business initiative Ensure high quality, trustable data Data quality rules Protect critical and sensitive data Requires data definitions to increase understanding Improves business operations Better decisions
4 Partial List of Data Governance Deliverables 4 Team Staffing Data Quality Rules Project Charter Data Quality Issues and Resolution Metadata Management Definitions Data Classification Policies Organization and Team Structure Data Security Policies Stewardship Data Access Policies Group Permissions Data Privacy Policies Data Compliance Policies Data Quality Policies Data Management Projects and Services Data Architecture and Data Integration Data warehouse And Business Intelligence
5 What If No Time for Full Blown DG? 5 Full blown DG normally takes a long time Deals with entire DG framework Normally requires expensive tools Large team Confusing priorities What to do? Our example will be the General Data Protection Regulation (GDPR)
6 What is the General Data Protection Regulation (GDPR)? 6 EU regulation to strengthen personal data protection Update of the EU Data Protection Directive (DPD) that redefines Personal data Individual rights Enforcement Heavy penalties Data Controllers vs. Data Processors Information governance and security Data breach notification and penalties Global Impact Companies worldwide
7 What Is Personal Data? 7 Any information relating to an identified or identifiable natural person ( data subject ); an identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to his physical, physiological, mental, economic, cultural or social identity. Many Types of Personal Data
8 Traditional Identifiers 8 Name Location data SSN Passport number Drivers license Credit card number Birthdate Telephone number Etc.
9 Digital Identifiers 9 IP address Cookies Mobile device ID Etc.
10 Biometric & Genetic Identifiers 10 Biometric Fingerprint scan Facial scan Retina scan Genetic Gene sequences
11 New Categories 11 Racial or ethnic origin Political opinions Religious or philosophical beliefs Trade union membership Health information
12 Other Requirements to Track 12 Explicitly give/withdraw consent for personal data usage Right to be forgotten (erasure) Right to see data Right to rectification Right to restrict processing The systems that process personal data Locations where personal data is processed Recipients of personal data (Access) Security methods for personal data Pseudonymization of personal data Rights related to automated decision-making & profiling Why should you care?
13 GDPR Affects Business Processes Customer Relationship Management Personal data to collect and store Personal data storage Personal data processing Personal data presented and transferred Personal data accessed Marketing Change from Opt Out to Opt In & prove it Similar proof for third-party data purchases All Software Privacy by default & privacy by design 13
14 3 Pieces of Data Identify You 14 DOB, postal code and gender virtual identity guarantee Web browsers provide at least 3 pieces of data Latest surveillance techniques all but impossible to detect or stymie HTTP injection Browser fingerprinting Let s see how GDPR affects typical analytics
15 By Gender and Location 15
16 Children By Gender, Location & Year 16 Geography City: Assens: Enrollment by Gender Boys Girls
17 By Gender, Location, Product Details Cars Sold by Year Geography City: Assens: Enrollment by Gender Boys Girls 17
18 GDPR Effect on Analytics 18 Cars Sold by Year Geography City: Assens: Enrollment by Gender
19 DG/GDPR Seems Overwhelming 19 GDPR requires a subset of DG processes and deliverables GDPR can be the foundation for DG Where to start? Instead of trying to do everything at once, Just do a slice
20 Laser Focus on GDPR 20 Concentrate only on the aspects relevant to GDPR Charter & Policies Classific -ation Security Access Privacy Compliance QG Dimensions DQ Rules & Issue Resolution Steward -ship Team Size GDPR Effort
21 How to Focus on GDPR Only Deals with People 21 Only data principles for people Limited Number of Elements Prioritize Systems Customer Facing First Small Team Single Priority Limited Issues/ Reports Scope
22 You May Already Have Tools to Help 22 Metadata repositories Data modeling tools Data dictionaries ETL Tools Etc. You may have to purchase a metadata tool You may have to build some tools
23 Consolidate 23 Bring GDPR compliance events into data warehouse Single source for compliance reporting
24 Links 24 Sample data protection policy Note only for an example. Seek professional advice when creating your own data protection policy MQFggtMAA&url=https%3A%2F%2Fiapp.org%2Fmedia%2Fpdf%2Fresource_center%2FITDonut_sample-DP-policytemplate.docx&usg=AOvVaw2WBMsY6DepF1k9HFMEysvY GDPR Home Page QFghyMAs&url=http%3A%2F%2Fwww.eugdpr.org%2F&usg=AOvVaw3QjjIT_L1TTLht3mTczeeZ GDPR assessment 99BQMQFggtMAA&url=https%3A%2F%2Fiapp.org%2Fmedia%2Fpdf%2Fresource_center%2FITDonut_sample-DP-policytemplate.docx&usg=AOvVaw2WBMsY6DepF1k9HFMEysvY Wikipedia on GDPR %2F%2Fen.wikipedia.org%2Fwiki%2FGeneral_Data_Protection_Regulation&usg=AOvVaw1iLbD0uYrznG2xM9SwFDyy
25 GDPR Glossary (1) Binding Corporate Rules (BCRs) a set of binding rules put in place to allow multinational companies and organisations to transfer personal data that they control from the EU to their affiliates outside the EU (but within the organisation) 25 Biometric Data any personal data relating to the physical, physiological, or behavioral characteristics of an individual which allows their unique identification Consent freely given, specific, informed and explicit consent by statement or action signifying agreement to the processing of their personal data Data Concerning Health any personal data related to the physical or mental health of an individual or the provision of health services to them Data Controller the entity that determines the purposes, conditions and means of the processing of personal data Data Erasure also known as the Right to be Forgotten, it entitles the data subject to have the data controller erase his/her personal data, cease further dissemination of the data, and potentially have third parties cease processing of the data Data Portability the requirement for controllers to provide the data subject with a copy of his or her data in a format that allows for easy use with another controller (more info here) Data Processor the entity that processes data on behalf of the Data Controller Data Protection Authority national authorities tasked with the protection of data and privacy as well as monitoring and enforcement of the data protection regulations within the Union Data Protection Officer an expert on data privacy who works independently to ensure that an entity is adhering to the policies and procedures set forth in the GDPR (more info here) Data Subject a natural person whose personal data is processed by a controller or processor Delegated Acts non legislative acts enacted in order to supplement existing legislation and provide criteria or clarity Derogation an exemption from a law Directive a legislative act that sets out a goal that all EU countries must achieve through their own national laws Encrypted Data personal data that is protected through technological measures to ensure that the data is only accessible/readable by those with specified access Enterprise any entity engaged in economic activity, regardless of legal form, including persons, partnerships, associations, etc. Filing System any specific set of personal data that is accessible according to specific criteria, or able to be queried Genetic Data data concerning the characteristics of an individual which are inherited or acquired which give unique information about the health or physiology of the individual Group of Undertakings a controlling undertaking and its controlled undertakings
26 GDPR Glossary (2) 26 Main Establishment the place within the Union that the main decisions surrounding data processing are made; with regard to the processor Personal Data any information related to a natural person or Data Subject, that can be used to directly or indirectly identify the person Personal Data Breach a breach of security leading to the accidental or unlawful access to, destruction, misuse, etc. of personal data Privacy by Design a principle that calls for the inclusion of data protection from the onset of the designing of systems, rather than an addition Privacy Impact Assessment a tool used to identify and reduce the privacy risks of entities by analysing the personal data that are processed and the policies in place to protect the data Processing any operation performed on personal data, whether or not by automated means, including collection, use, recording, etc. Profiling any automated processing of personal data intended to evaluate, analyse, or predict data subject behavior Pseudonymisation the processing of personal data such that it can no longer be attributed to a single data subject without the use of additional data, so long as said additional data stays separate to ensure non attribution Recipient entity to which the personal data are disclosed Regulation a binding legislative act that must be applied in its entirety across the Union Representative any person in the Union explicitly designated by the controller to be addressed by the supervisory authorities Right to be Forgotten also known as Data Erasure, it entitles the data subject to have the data controller erase his/her personal data, cease further dissemination of the data, and potentially have third parties cease processing of the data Right to Access also known as Subject Access Right, it entitles the data subject to have access to and information about the personal data that a controller has concerning them Subject Access Right also known as the Right to Access, it entitles the data subject to have access to and information about the personal data that a controller has concerning them Supervisory Authority a public authority which is established by a member state in accordance with article 46 Trilogues informal negotiations between the European Commission, the European Parliament, and the Council of the European Union usually held following the first readings of proposed legislation in order to more quickly agree to a compromise text to be adopted.
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