Automating Privacy and Compliance

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In the digital age, the deluge of data is relentless. This burgeoning data realm, bolstered by the dawn of generative AI, demands meticulous choreography to remain coherent and valuable. As the complexity of ecosystems multiplies, so does the imperative to tether this wealth of information to the bedrock of privacy and protection.

Michelle Dennedy, Jonathan Fox, and Thomas Finneran write in “The Privacy Engineer’s Manifesto” that “complexity — in requirements, systems, and data uses — has led to increasingly sophisticated personal data management and ethical issues, the downing of the personal information service economy, and privacy engineering as business critical and customer satisfaction imperative and necessity.” The recent pandemic’s push for rapid drug discovery illuminated the delicate dance of data sharing, where patient information became both a beacon of hope and a bastion of confidentiality. Striking a balance between innovation and integrity is not just a goal, but a necessity, ensuring that as our data footprint expands, it leaves a mark of progress, not peril.

Privacy Delivery Requirements

In the warp and weft of the modern data tapestry, organizations walk a tightrope strung between the twin towers of data protection and utility. They must deftly navigate the conundrum of utilizing vast data reserves for decision-making while safeguarding the sanctity of privacy. This process must include the following:

  • Ensuring compliant, authorized, fair, and legitimate processing of personal information and private data.
  • Processing only occurs with appropriate privilege.

Without question, Dennedy, Fox, and Finneran are correct when they assert that information is personal if identity can be correlated with activity. Personal identifiable information (PII) exists if the correlation is viable and probable or if identity and activity information exist in the same repository. For this reason, privacy by design holds that privacy must be proactive, not reactive; be the default setting; embedded into design; have full functionality; be end to end; be visible and transparent; and respect for user privacy.

These notions remain foundational, but the mantra “privacy by design” must evolve, adopting proactive extensions that are not just part of the system but its foundation. As cloud data explodes, leaving privacy to each system is a non-starter. Transparency and visibility become not just design principles but operational mandates, ensuring that the sanctity of personal information is not a byproduct, but the cornerstone of system architecture. As data proliferates and diversifies, it calls for a systemic vision that transcends individual platforms, embedding privacy into the DNA of the entire data ecosystem, and safeguarding the lifecycle from inception to retirement. This isn’t just about compliance; it’s about crafting a legacy of trust in the digital domain.

As we stand at the crossroads of a data-driven era, the mandate is clear: Privacy must be more than a checkbox, it must be the very pulse of our systems. Fair and responsible processing of data is not just ethical, it’s essential. In touching private information, we touch lives, and so it necessitates a framework where access is not just controlled, but conscientiously privileged. The concept of privacy by design requires fortification — extensions that are not mere additions, but integral, proactive layers woven into the fabric of system architecture. In the burgeoning landscape of data, where variety often breeds inconsistency, the call is for uniformity — transparent, visible mechanisms that guard data across the sprawl of an entire estate. We need a holistic, systemic approach, one that enshrines privacy at every touchpoint, protecting the data’s integrity throughout its lifecycle. This is the evolution of privacy — a vision that honors the trust placed in our digital custodianship.

Where Automation Helps GDPR Compliance

In the quest for data sovereignty, FAIR processing is not just a principle, but a bulwark against the misuse of personal data. It calls for a paradigm where the minimum necessary data meets the user, reducing the shadow of bias and the risk of overexposure. In the wake of inevitable breaches, the integrity of our systems is tested — yet, with robust design, confidentiality can be upheld, even in the face of vulnerability. Identifying sensitive data becomes a proactive shield, not a reactive fix. Automation emerges as the linchpin in the right to erasure, ensuring compliance not as a burden, but as a seamless aspect of the data lifecycle. GDPR’s framework doesn’t merely demand adherence; it inspires a shift towards a culture where data protection is ingrained, and every potential risk is a challenge pre-empted. This is our commitment to privacy, a resolve to weave security into the very DNA of our digital ecosystem.

Healthcare Payer Example

The transformation of a major healthcare payer into a digital-savvy entity epitomizes the strategic pivot necessary in today’s data-driven world. The company confronted its business issues head-on, seeking to innovate with data while safeguarding Protected Health Information (PHI). The resolution involved implementing fine-grained data protection and advancing transparent security measures, which transcended traditional coarse-grained access controls and mitigated data duplication. By adopting a comprehensive security overview and simplifying audits, the payer not only contained data proliferation, but also enhanced accessibility and manageability. The business impacts were substantial: a reduction in dataset proliferation protected against both external breaches and internal threats, while the discovery and control of PII and sensitive data were fortified. The organization streamlined its IT operations, reducing the burden on engineers and administrators, thereby demonstrating a case study in balancing data accessibility with stringent security protocols — an equilibrium critical for the future of digital healthcare.

What Does Success Require?

Success in managing PII within an organization demands a blend of strategic automation and proactive oversight. The cornerstone of such a strategy is the automation of PII discovery — leveraging technology to systematically scan the entire data estate, identifying and tagging sensitive information. This process not only harnesses existing governance frameworks, but also extends them, ensuring no fragment of PII goes unnoticed. Complementing this is the simplification of policy creation and enforcement; policies that are both robust and easy to implement are essential for maintaining control over data security. Finally, success is underpinned by the ability to manage and audit data handling practices proactively, not reactively. This means anticipating risks, streamlining compliance, and being prepared to respond to potential breaches with agility. It’s a holistic approach where the end goal is clear: to establish a secure, compliant, and efficient PII management system that stands the test of time and the scrutiny of governance.

Discover PII Across All Data Systems

The process of uncovering personally identifiable information (PII) across all data systems is a foundational step in the journey toward comprehensive data privacy and protection. The automation of PII discovery is not just about detection — it’s the precursor to a series of actions aimed at reducing risk and ensuring compliance with data protection regulations. Once PII is identified, privacy professionals can assess the risk associated with data elements, making informed decisions about class attributes for access authorization. This leads to a crucial phase where data needing depersonalization or de-identification is pinpointed, allowing organizations to minimize the amount of sensitive information they hold. By depersonalizing or de-identifying data, organizations can significantly reduce the potential impact of a data breach, as the data would hold little to no value for unauthorized viewers, thus fortifying privacy and reducing the risk of harm to individuals. 

Simplify Policy Creation and Control

Simplifying policy creation and control is paramount in today’s data-driven landscape. The traditional method of writing policies as code shifts the burden from governance teams to data engineers and database administrators, which is not optimal. The solution lies in automation, especially in the discovery of PII, which sets the stage for assessing risks and determining necessary actions like depersonalization or de-identification. It’s a misconception that certain roles should have unfettered access to all data, as recent breaches often exploit such privileges.

To achieve streamlined policy management, organizations should implement global policies and controls that apply uniformly across all systems. This ensures that privacy rules, once defined, are automatically integrated into metadata repositories, aligning with privacy policies and standards like GDPR or CCPA. Such an approach also prevents unauthorized access, avoiding the pitfalls of a single point of failure and ensuring transparent, consistent enforcement of privacy protocols. This shift not only aids in compliance, but also facilitates business agility, enabling quicker integration of new data sources and applications while safeguarding against penalties and fines.

Manage and Audit Proactively

Proactive management and auditing are cornerstones of a robust privacy and compliance strategy. Embracing Privacy by Design, organizations must manage privacy throughout the entire data lifecycle, allowing for continuous policy conformance, improvement, and control. This proactive stance involves integrating audit trails and reporting data into existing security frameworks, enhancing transparency and enforcement.

The shift to no-code solutions enables governance teams to understand and enforce privacy without the need to decipher complex code, such as SQL statements. This approach secures against inappropriate access and maintains consistent privacy practices across all systems, facilitating the adherence to privacy principles.

Dashboards play a crucial role, offering real-time insights into queries, lifecycle stages, and potential anomalies in data usage, which is essential for proactive auditing and managing compliance. As regulatory demands intensify, especially with the advent of generative AI, the need for systemic controls becomes more evident. Rather than a fragmented, system-by-system approach, which is both time-consuming and costly, a unified system is imperative. Such a system ensures consistent application of privacy rules across all data instances, which is vital as organizations scale and the cloud facilitates rapid data proliferation.

Parting Words

In the sprawling expanse of the cloud, where data multiplies unchecked, meeting regulatory requirements becomes a Herculean task. Success in privacy and compliance is not won through a piecemeal, reactive approach — it’s not a game of “whack-a-mole” with data points. Instead, a holistic, unified solution is necessary — one that treats privacy and compliance not as isolated issues, but as interconnected cogs within a greater system of systems. This integrated approach ensures coherent and consistent application of policies across the entire data landscape, simplifying governance and fortifying data protection.

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Myles Suer

Myles Suer

Myles Suer, is the leading influencer of CIOs, according to Leadtail. He is the facilitator of #CIOChat. The chat has executive level participants from around the world in a mix of industries including banking, insurance, education and government. Myles publishes on a number of sites, including a prior weekly column at as well as articles published in ComputerWorld, Cutter Business Technology Journal, and COBIT Focus. He is the Strategic Marketing Director at Privacera.

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