Sophie Chase-Borthwick, Director of Data Ethics and Privacy, Calligo
Privacy is essentially just a data security problem, right? Surely, the requirement to act more responsibly with personal and sensitive data equates to protecting it better, encrypting it and preventing hacks and leaks?
Many financial businesses assume exactly this, and that data privacy, whether GDPR or California’s new CCPA, is merely an IT security problem. However, it goes far wider than that.
For the chief information security officers (CISOs) that have been assigned responsibility for privacy within their organisation, it can often be seen as an unenviable task. Few boards and and executive teams understand the detail of what is required for GDPR adherence or Privacy by Design to assign enough or the right resource to the task.
In fact, we regularly hear stories from financial services organisations of all sizes about shoddy approaches to data privacy, especially GDPR, with some assuming that just because they have a data security function, adherence is a given.
However, as an experienced CISO, you will understand that privacy is not as simple as ring-fencing your data. You will appreciate that because GDPR in particular requires the responsible management and use of data, just as much as its responsible protection, that a privacy strategy needs involvement from every part of a financial organisation, including marketing, HR, sales etc.
But many businesses did not think like this. Or more accurately, many CISOs were fully aware of the extent of the task, but were not given the time or resource to address it appropriately. Many were forced to focus on the parts they could fix the fastest and the easiest, predominantly technology and data protection, leaving major gaps in processes and people – the two other equally-important pills of adherence.
Others were bending over backwards to cover the basics of the new requirements, but saw their wider security strategies either derailed or delayed in the process, leaving many financial businesses more susceptible to security breaches than they were before. These are real scenarios that we have seen time and again amongst our clients.
So, how is it possible to balance data privacy with wider security strategy? Many argued when GDPR came into force that it represented a huge opportunity for those in CISO roles to change the perception of their input and value to a business; from simple data protection to instead safeguarding data across its entire lifecycle.
But how can you put this into practice? How can a CISO build the strategy that achieves the immediate data privacy goal, while enhancing – not weakening – wider data security initiatives, and their own standing?
Assess your business holistically
There are eight domains that require addressing for a successful privacy strategy: governance and accountability; risk management; security management; third party management; incident management; personal information management; rights of data subjects; and finally, understanding the scope of your organisation as it pertains to the relevant legislation.
The most obvious observation for many CISOs will be that many of these areas are outside their traditional scope. However, they all need equal attention and they are all unavoidably part of the project they are leading. The trick is to not let yourself focus on only the more easily-addressed “home turf” security areas, nor be drawn by the business too far into the non-security areas.
Ask for help
Perform a GAP analysis
Before you can even think about aligning your organisation to a privacy strategy, you must identify your baseline and areas of improvement. What are the minimum requirements within each of the eight areas for your business to be in line with the legislation facing you? And, what constitutes particularly robust observance? Finally, where on this spectrum are you aiming for and how does that compare to your current state?
Present your action plan
The GAP analysis will have provided you with a starting point and a series of non-conformances to address. The next step is to prioritise the remedial tasks required and plan how they will be executed. It is however imperative to demonstrate that the plan is tied to, but not wholly based on, the security strategy. Sales, marketing, HR, IT etc. must all understand that they have equal parts to play, and be equal in their accountability.
Secure wider resource
The final part of the process is to identify the most suitable individuals to assist. This controlled delegation maintains the CISO’s position as the lead on the project, ensures good project management and execution, while also safeguarding the security team’s resources.
It’s clear that a privacy strategy is an organisation-wide initiative and encompasses all areas of technology, people and processes. It requires far more than building higher walls around your data, or simply gaining renewed consent from customers. However, it’s important to remember that this will not be widely understood, and given it is commonplace post-GDPR for CISOs to be handed responsibility for privacy, you will need to take the initiative on a whole host of procedures and processes that span your entire enterprise – and may not be within your comfort zone.
However, get it right and you will engender more trust from within your customer base – an important commercial outcome that you can take no small amount of credit for.
HOW TO MANAGE YOUR CASH FLOW IN UNCERTAIN TIMES
While the world is constantly changing, probably at a faster pace now than ever before, businesses need to manage cash flow and costs to drive success in uncertain times, says Matthew Thorpe, partner at Haines Watts Essex.
Managing people and expenses
There are certain costs that you just can’t avoid as a business – to keep your operation running seamlessly, but scrutinise the detail and cut down on any non-essential expenses. Check things like your SaaS subscriptions and look out for costs that auto-renew and if you do cancel, remember to also cancel your direct debits too.
You might want to put a freeze on hiring new people, but ensure that other roles and responsibilities are clearly and efficiently assigned across your team. The Coronavirus Job Retention Scheme (CJRS) has been introduced by the Government to help UK employers access support to continue paying part of their employees’ salary to avoid redundancies. Affected employees are classed as “furloughed workers”.
Once furloughed, the employee cannot work or they will not qualify for the scheme. For businesses that perhaps need to go further, there may be some roles they don’t need any more, but businesses should work sensitively with people to manage this.
Cash is king
In uncertain times, owner managers will need to keep operations going to ensure financial stability. You should look to manage debt more efficiently by negotiating extended payment terms with creditors. You could also renegotiate loans for longer repayment terms to give yourself a lower monthly payment, helping the business to set some cash aside each month.
As a business owner, you need to create a cash flow projection and update this regularly if you are to improve things. You can do this using financial information to create a picture of how the business will look in the next 12 months. The forecast needs to show revenue sources and expenses, which will show the ups and downs of business income and can be used to make sure that enough finance is in place.
While banks and other finance providers recognise that the cashflow of a business may be disrupted by the impact of Covid-19, they are still going to want to see that you are viable and continue to trade in these uncertain times. Make sure your business is organised and don’t let disorganisation cause unnecessary issues. You can evidence this by having detailed forecasts; current order books and projections (as best as possible).
Having instantly accessible, accurate financial information allows you to plan effectively, spot issues before they become problems and manage your money in the most efficient and rewarding way.
Software is now incredibly user-friendly and accessible from anywhere. For a business owner embracing the technology, this means:
- Invoicing can be done instantly when a job is complete, emailed to the customer with an easy to use link to a payment platform.
- Comparison websites can automatically monitor and help maintain lowest cost for things such as light & heat, insurance etc.
- Technology can be used in place of face-to-face meetings. It can also enable them to adapt production lines to different demands.
All of these things and more, used properly, can make managing your business finances quicker, easier and often cheaper. You will also be able to bring clarity to where your business stands and prepare for the next steps.
HOW FINANCIAL SERVICES CAN GET TO GRIPS WITH RISING SUPPLY CHAIN RISK
By Alex Saric, smart procurement expert, Ivalua
UK businesses have never been more dependent on their suppliers to help them deliver goods and services to their customers. Be it retail, manufacturing or financial services, suppliers have a vital role to play when it comes to innovation and meeting customer expectations. However, as supply chains become increasingly global, businesses are potentially exposing themselves to more risk than ever before.
This is especially true in financial services. Whether it’s the impact of geopolitical events like Brexit or global tariff wars, supply shortages, security or the businesses impact on the environment, an organisation’s failure to identify and mitigate risk could see millions wiped off its share price, and its corporate reputation left in tatters. Risk can present itself anywhere and at any time, so financial services firms must be ready to address it. However, many simply don’t have the ability to evaluate suppliers for risk factors, leaving them wide open to business operations being hindered, or being slapped with financial penalties.
More suppliers, increasing risk
One reason why financial services firms aren’t able to evaluate suppliers is the breadth and scale of today’s supply chains. For example, French oil company Total said in in a recent human rights briefing paper that they work with over 150,000 direct suppliers worldwide. This is just one example of how large and varied the roster of partners has become. Research from Ivalua has found that financial services businesses on average are working with around 3,600 suppliers annually, which is evenly split between UK-based and international partners. That number is expected to rise, with 60% expecting the number of suppliers they work with to rise.
The expanding nature of suppliers is only going to expose financial services firms to more potential risk than ever before, yet 78% say they face challenges gaining complete visibility into suppliers and their activities.
A lack of supplier visibility leaves businesses unable to identify and mitigate against supply chain risk. In fact, almost three-quarters (73%) of financial services firms have experienced some type of risk during the last 12 months. These include; supplier failure (43%), environmental impact, such as pollution or waste (35%) and supply shortages (45%). Supply shortages can be among the most damaging to a business, as seen by both the KFC chicken shortage which closed stores, and the summer 2018 CO2 shortage which caused companies such as Heineken and Coca-Cola to pause production, impacting supply across Europe during the World Cup.
Businesses unprepared for the worst
One way financial services firms can better prepare for risk is to ensure they know what to plan for to reduce the impact. However, whilst some say they have a contingency plan in place to deal with risk, many of them are unprepared. Financial services firms admitted to not having comprehensive and deployed contingency plans in place to prepare the supply chain for risk such as; natural disasters (68%), supply shortages (67%), geopolitical changes (65%), environmental impact (63%), supplier failure (62%) and modern slavery (50%).
In order to effectively prepare for these types of risks, it’s vital that financial services businesses fully understand their suppliers, their business environment, global variations in regulations, geopolitics, and a host of other factors. But for many, there are multiple challenges when it comes to gaining this understanding. A prevailing factor is an inability to gain visibility into all suppliers and activity because supplier management data is stored in multiple locations and formats, making insights difficult to access. This leaves teams unable to review supplier activity and assess compliance.
Making supplier management smarter
It’s imperative that financial services businesses are able to respond or prepare for supply chain risk. Clearly, much more needs to be done to ensure they have complete visibility of suppliers, especially in an era where regulators can levy heavy fines for GDPR breaches and scandals spread in minutes over social media. These types of risks can be reduced in the future if procurement teams have a 360-degree view of suppliers which will help with contingency planning and risk management.
For example, in the instance of supply shortages, plans could be put in place that identify alternative suppliers to ensure any shortages do not impact end users. This type of supplier collaboration is paramount when it comes to managing and mitigating against supplier shortages. When it comes to regulations, financial services firms can’t allow a lack of visibility to limit their ability to ensure all suppliers are compliant.
To do this, teams must take a smarter approach to procurement that gives complete visibility into suppliers throughout the supply chain. This will allow financial services firms to identify and plan for risk, reducing the potential damage, and ensuring they are working with and awarding business to low-risk suppliers. Supply chain risk is rapidly becoming an overarching concern for financial services firms, but by providing the ability to assess suppliers, they will have all the insights they need to mitigate the impact on business operations.
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