Integration of Privacy and IM Programs

Information governance programs and information privacy programs share many common elements, goals, and employees. Many organizations find that integrating privacy and information governance, and coordinating these two initiatives, despite relatively different goals, can minimize duplication of work on all sides and improve efficiency in both cases. Let's look at some of the similarities and explore how privacy and IM can help each other.

Core Program Requirements

Information governance and information privacy requirements are very similar through M&A advisory, although not identical. Both start with Policies and Procedures, essentially the basic operation of the programs and how they work on a day-to-day basis. In addition to these, information governance requires a records retention schedule; a policy document that defines an organization's legal compliance and record-keeping requirements. Information management roles are also required, which have counterparts in privacy roles in information privacy programs. Both must handle legal checks, and both establish data cards to perform those checks, although these data cards are different.

Understanding governance

Information authority and privacy control are also essentially quite similar. Both require orientation to the users of the given program and some such procedures. By integrating the two domains, an organization can ensure that its users, as well as their own business interests, are protected from bad actors and legal repercussions from all sides. A strong privacy policy and information management policy serve as the foundation for governance and are supported by detailed and clear procedures for certain day-to-day and rare situations, such as opt-in/opt-out privacy policies or standards distribution of information.

Of course, all these policies and procedures must also align with a variety of privacy laws in the different nations in which your organization operates.

Roles and responsibilities

A clear command structure and accountability system are also essential to information management and privacy programs. Chief Information Officers (CIOs) and Chief Privacy Officers manage the entire department and are considered responsible for the divisions. Records managers and analysts ensure that records are securely managed and secured on a broad policy basis and log those responsible for the day-to-day use of records. Similarly, on the privacy side, there should be privacy analysts and delegates who ensure privacy compliance in all its nuances.

These groups must also work with other parts of the organization; namely, legal teams who ensure the organization is compliant with privacy and records management laws, senior executives who deal with strategic management and coordination within the organization, and ethics and risk compliance experts who help the company manage ethical privacy issues, and information technology stakeholders who might be responsible for ensuring that electronic records, especially those involving confidentiality, are stored efficiently and securely while maintaining appropriate accessibility.

Verifications

Internal audits of privacy records and services can be extremely helpful in determining internal weaknesses before they become problematic with the help of an M&A advisor. By identifying these weaknesses early on, losses and security and privacy breaches can be prevented even before they occur.

Information Governance Audits

Information governance audits are performed in several stages. The first involves determining the context of the verification. This is your “measurement tool”: it's where you set the standards and nature of the audit, as well as the policies and methods you review. This is followed by the audit itself, to see if current methods meet the standard required for the organization. Next, auditors should analyze the results, noting the strengths and weaknesses of the current information governance program, and where program policies need to be changed.

Privacy Checks

Privacy audits require several steps, like government information audits. First, the context of the audit must be defined. It is a comprehensive analysis of current privacy laws and best practices to ensure that the audit can effectively and smoothly identify issues in current privacy policy and programs. The next step is to perform a privacy risk assessment. This is a cross-sectional analysis of all places where information is distributed in cases where there are privacy risks.

Next, the confidentiality categories must be determined, such as minor or non-minor records, financial records, medical or educational information, and information that does or does not identify an individual. By effectively identifying these categories and the risks around them, action plans can be created to mitigate the risks to the organization and its subjects and customers. The data flow can then be mapped; this helps to determine the main points of vulnerability in the organization's privacy policy.

Finally, the above steps can be linked to determine where the privacy of information is affected by the policies in place. action plans can be created to mitigate risks to the organization and its subjects and customers. The data flow can then be mapped; this helps to determine the main points of vulnerability in the organization's privacy policy. Finally, the above steps can be linked to determine where the privacy of information is affected by the policies in place.

Action plans can be created to mitigate risks to the organization and its subjects and customers. The data flow can then be mapped; this helps to determine the main points of vulnerability in the organization's privacy policy. Finally, the above steps can be linked to determine where the privacy of information is affected by the policies in place.

Verification merging

By combining the checks, a more efficient and comprehensive check can be created, reducing the cost implications and effectiveness of both. The results can then be seen together, with separate issues highlighted so that mitigation strategies can remain in close harmony.

Data cards

Data mapping is a method of determining risk to customers and parts of your organization by identifying the flow of information, how the information is stored, and all points at which it can be accessed. By doing this, an organization can effectively pinpoint areas where privacy or information security might be breached and can take new strategies to mitigate those risks. A complete data card may include:

• Type of information
• Application of Record Series / Classification of Personally Identifiable Information
• Storage location
• Jurisdictional requirements for document retention
• Personal Information Captured
• Method and means of capture
• Access and access controls
• Creation system
• Storage locations
• Inter-connected and affected systems
• Risks (as in a privacy risk assessment)

Training and education

Training on audits, information management, and confidentiality of information should be ongoing and emphasize good workplace policy. If people are not educated in the hows and whys of politics, they naturally become weaker and easier to exploit by malicious individuals. Annual training should also be created so that information and privacy policy updates can be easily disseminated throughout an organization. This content can also be incorporated into other training methods with the organization, especially those recently or initially involved with the organization.

Privacy and IM integration

For information management and privacy policy to work, they must be an integral part of the organization's culture, from the bottom up, and they must be both ongoing and responsive to the needs of the organization and those which it serves. Both programs benefit greatly from being integrated to consolidate the weaknesses of both parties and speed up the verifications of their weaknesses. With the proper management of both parties, the organization's legal, financial, and informational risks can be significantly minimized and reduced.