How do you benchmark your data privacy risk assessment against best practices or industry standards?

The IAPP has two flagship resources that will help organisations benchmark their privacy risk and broader privacy governance work: - IAPP-KPMG Privacy Risk Study 2023: https://iapp.org/resources/article/privacy-risk-study-summary/ (Past versions of the Study, going back to 2015, are available at that link.) - IAPP-EY Privacy Governance Report 2023: https://iapp.org/resources/article/privacy-governance-report/ (Past versions of the Report, going back to 2015, are available at that link.)

Protecting customer privacy is critical in the finance industry. In my experience, we define particular measurements and criteria to evaluate our success when evaluating data privacy concerns for a banking project. In doing so, we improve our data privacy maturity and stakeholder trust by streamlining our benchmarking process and using resources effectively.

Establish metrics when it comes to privacy can be challenging. You cannot set metrics based on the amount of reviews performed---because you could be the office of rubber stamp if that was the defined metric. The best metrics instead try to quantify the amount of impact of privacy.

Some of the steps can be : 1. Come up with the privacy policies, objectives 2. Come up with risk management policies and procedures for Data privacy whcih can include your input from DPIA ( Data processing impact assesssment) 3. Align your privacy framework with GDPR, HIPAA, CCPA, PDPA.. In fact we can follow ISO 27701:2019 Std. 4. Identify data inventories and data flow diagram 5. Apply the data minimization, Data consent mgmt , subject right policies immensily. 4. Apply all the org and tech measurements and controls to safeguard the privacy data. 6. Continously review and monitor. 7. Bring in the Employee awareness in the organization.

Em uma comparação de riscos com outras empresas é necessário identificar as áreas de atuação das empresas, o conjunto de dados e os tipos de dados (pessoais ou pessoais sensíveis), pois cada área pode ter suas regras e disposições específicas, logo isso irá interferir no benchmarking. When comparing risks with other companies, it is necessary to identify the companies' areas of activity, the set of data and the types of data (personal or sensitive personal), as each area may have its own specific rules and provisions, so this will interfere with the benchmarking.

In aligning our data privacy risk assessment with best practices, our focus extends beyond conventional benchmarks to a nuanced consideration of regulatory compliance and ethical business conduct. When selecting benchmarking partners, we prioritize industry peers, regulators, customers, and experts, ensuring a diverse yet relevant comparison. Gathering insights through surveys, interviews, reports, audits, and online platforms, we strive for a holistic evaluation. Crucially, we approach the legal and ethical dimensions with heightened scrutiny, recognizing the delicate balance between accessing valuable insights and upholding privacy principles.

When evaluating data protection standards, I typically begin my gap assessment by consulting a regulatory authority. While I leverage competitors for marketplace analysis, it's crucial to avoid a race to the bottom, as some may have subpar standards.

Frameworks are key! But let’s talk about how to actually do it. If you really want to be crazy like me, open them side by side and compare. The level of detail that doing so reveals is really something. But I would not recommend that because it’s not practical and very time-consuming. But investing in the proper placement of these assessments against these frameworks from the beginning will help you get through them quicker. A quick note, all frameworks available are great but I find that it’s easier to stick to one framework across functions because the language used in each framework differs and can cause confusion. Keep it simple and effective. A data privacy tenet.

Obtaining industry-recognised certifications or following the guidelines promulgated by leading data protection authorities like the Singapore Infocomm Media Development Authority’s Data Protection Trustmark certification organisations such as the ISO or AICPA will certainly put programs in a good position.

In alignment to data privacy risk assessments you can compare your practices against established frameworks like ISO/IEC 27701, GDPR, or NIST Privacy Framework. Ensure alignment with legal requirements, assess data protection measures and regularly update your privacy policies based on evolving standards.

Benchmarking data privacy risk assessments involves comparing practices against industry standards. To analyze and compare data, utilize tools like spreadsheets or dashboards. Identify patterns, trends, and gaps in the collected data, considering context and limitations. Caution against assumptions and generalizations, emphasizing a thorough understanding of sample size, time frame, scope, and data quality. This meticulous approach ensures a comprehensive evaluation aligned with best practices, enhancing the effectiveness of your data privacy risk assessment.

Review Benchmarking Criteria: Begin by reviewing the benchmarking criteria provided by your chosen sources, such industry standards, regulatory guidelines, or best practices frameworks. Identify the key areas focus and performance indicators against which your organization will be evaluated. Assess Current Practices: Evaluate your organization's current data privacy practices and risk assessment methodologies against the benchmarking criteria. This may involve conducting a gap analysis to identify areas where your organization meets or falls short of best practices or industry standards. Collect Data: Gather relevant data and information needed to assess your organization's data privacy practices. This may include policies and procedures.

Na empresa em que atuo criamos uma planilha com vários requisitos de segurança da informação e privacidade de dados que foram retidas de normas ISO (27002, 27701), NIST, além de critérios retirados de benchmarking como governo digital, instituto Ethos e ISE B3. Através dessa planilha criamos o índice de privacidade da empresa e assim conseguimos acompanhar a nossa evolução quanto a privacidade e proteção de dados.

After collecting data from benchmarking partners and sources, analyze and compare it using tools like spreadsheets, charts, dashboards, or software. Identify patterns, trends, gaps, strengths, and weaknesses in the data. Consider the context and limitations, including sample size, time frame, scope, and quality. Refrain from making assumptions or generalizations based solely on the data, recognizing its context and potential limitations.

When benchmarking your data privacy risk assessments, it's important to adopt a qualitative approach alongside quantitative metrics. Instead of solely relying on software tools and KPIs, consider incorporating expert evaluations and peer reviews into your benchmarking process. Engage with industry forums and networks to gain insights into how similar organizations handle comparable challenges. This will provide a richer, context-driven understanding of where you stand in terms of best practices. Additionally, ensure that your assessments consider the unique aspects of your organization's data handling practices, as one-size-fits-all solutions can overlook critical nuances.

Privacy Impact Assessments typically vary based on the sector, criticality of the data, data security controls, applicable regulations etc. While you carry out Impact Assessments compare your Impact assessments with the above cases from various segments of Industry and benchmark them.

Improving your data privacy risk assessment involves evaluating each opportunity based on feasibility, impact, urgency, and alignment with your goals. This can be achieved using a decision matrix to rank each opportunity on these criteria, and calculating a score to prioritize them. Cost-benefit analysis can help understand the financial implications of each opportunity. Risk assessment can shed light on potential drawbacks. Once ranked, focus on high-value, high-priority opportunities that align with your objectives. Regularly revisit the assessment to account for changes in the data privacy landscape. This systematic approach ensures a comprehensive, continuous improvement in managing data privacy risks.

Conduct a Gap Analysis: Start by conducting a comprehensive gap analysis to compare your organization's current data privacy practices and risk assessment methodologies against the benchmarking criteria established by industry standards or best practices frameworks. Identify areas where your organization falls short or where improvements are needed. Assess Regulatory Compliance: Evaluate your organization's compliance with relevant data privacy regulations, such as GDPR, CCPA, HIPAA, or industry-specific regulations. Identify any gaps or areas of non-compliance that need to be addressed to align with regulatory requirements.Review Incident and Audit Findings: Review past incident reports, audit findings, and compliance assessments.

An effective benchmarking process for data privacy risk assessments involves not only aligning with industry standards, but also leveraging tailored benchmarks based on your specific industry and data types. After identifying gaps through this comparison, it's crucial to prioritize improvement opportunities based on a clear ROI framework. Consider the risk reduction each improvement brings versus its implementation complexity. Strategic prioritization should reflect your most critical data protection needs, ensuring compliance and safeguarding stakeholder trust.

Comparing the data privacy risk assessment to best practices or industry standards can help organizations identify areas for improvement and enhance their data privacy practices by considering: a) Identify data privacy best practices, such as GDPR in Europe, LGPD in Brazil, and CCPA in California, as well as organizations like IAPP that provide guidance and standards for data privacy. b) Evaluate the result of the organization's current risk assessment to identify areas that can be improved. c) Compare the organization's risk assessment with best practices to identify areas where the organization may be below acceptable standards or where gaps exist in its data privacy processes. d) Implement improvements based on benchmarking.

One thing I have found helpful is getting buy-in from the C-suite level (or HoDs where relevant) where the improvements needed are likely to change workflows, systems and processes. Buy-in from the top can help increase buy-in from the rest of the teams as they are the key implementers of the actions identified.

Develop Action Plans: Based on the prioritized improvement opportunities identified through the benchmarking process, develop detailed action plans outlining specific tasks, timelines, responsible parties, and resource requirements for each improvement action. Assign Responsibilities: Assign clear responsibilities to individuals or teams responsible for implementing each improvement action. Ensure that roles and responsibilities are clearly defined, and that team members understand their roles in driving the implementation process forward. Allocate Resources: Allocate the necessary resources, including budget, personnel, technology, and other support, to support the implementation of improvement actions. Ensure that resources are sufficient

Monitoring progress in privacy benchmarking involves a clear action plan. Each improvement action should have defined tasks, responsibilities, resources, and timelines. Indicators or key performance indicators (KPIs) help gauge progress. For example, a reduced number of data breaches can be an indicator of improved data security. Assign clear roles and responsibilities for each task and communicate these to your team and stakeholders. Regularly review the progress of each task against the planned timelines and make adjustments as necessary. Employ tools like Gantt charts or project management software for effective monitoring. Through this structured approach, you can ensure constant progress in your privacy benchmarking efforts.

Uma excelente maneira de medir a eficiência e eficácia da melhoria realizar é acompanhar o indicador, caso na possua um base histórico para comparar os resultados antes da melhoria com o depois é importante criar um indicador de acompanhamento desse processo para que seja possível mensurar o ganho com novas melhorias que podem ocorrer nesse processo analisado. Por exemplo: número de solicitação de optout após uma mudança no site ou no sistema de gerenciamento do optin e optout.

Implement improvement actions based on your prioritized opportunities. Develop a clear action plan with tasks, responsibilities, resources, timelines, and indicators. Assign roles, communicate with your team and stakeholders, track progress using metrics, and adjust actions as needed for ongoing improvement in your data privacy risk assessment.

First of firsts, understanding the data flow is the most critical factor in Privacy assessments. Through this you can determine: The purpose why is it taken and where the data is being used. The type and extent of personal data should be taken in order to fulfill the work requirement (ensures Data minimization). Gathering the accurate and updated perosnal data, Limiting the storage of data with purpose Applying relevant safeguards in order to mitigate the probable risk to data and closing the risk.

It's useful to have a community of Worldclass professionals that you can rely on to peer review your work or utilise as a sounding board and even ask for suggestions and guidance. That's one of the reasons I created the Privacy Pros Community. It let's us maintain a world-class standard with our DPIA and PIA's and sometimes find controls and solutions that you might never have considered otherwise.

It is necessary to share the results of the benchmark with the relevant stakeholders. In addition, the result must be actionable, so that the PDCA cycle can be put into practice and the benchmark can be used as a tool to improve the organization itself.

This is, IMO, a funny question, certainly under the GDPR, assuming "data privacy" means "data protection". Is "industry standard" the appropriate way to approach your data protection programme? I am certainly not convinced. There are very specific legal requirements that you meet or you don't, and they are valid at a point in time. I'll go further, there are industry guidelines for members of IAB, and these guidelines have proven to be illegal. So, is this the type of benchmark you want to follow? I suggest that the DPO starts by monitoring the key components under their responsibility.

When you benchmark risk assessment tools, you will get more accurate results if you have learned which are your most valuable “assets” and what are the consequences of threats, attacks and breaches. In terms of weighting the consequences, (damages or injuries, losses and liabilities) preeminence should be given to data subjects over our business. What counts in the end for data protection are data subjects.