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Review Your Data Protection Compliance Checklist for These 3 Steps

Originally published by New Context.

Every major enterprise has a data protection compliance checklist. It’s a necessity to stay up to date in any industry. Compliance failures can create a lot of problems, from fines and penalties to lost client trust. That checklist is the first line of defense to ensure adherence to a complex list of regulations.

However, there are some steps that organizations miss when they’re attempting to establish a robust protocol. That’s because they usually base their lists on directives from a legal department without considering some of the more technical aspects of data compliance. A good data protection compliance checklist also incorporates some use of open policy agent, regular follow-up, and remediation steps in the event of a breach.

Basic Components of a Data Protection Compliance Checklist

The best way to establish data protection solutions is to leverage the basic steps listed in the General Data Protection Regulation. While the GDPR only applies to data from activities in the European Union, it’s a good model for treating all sensitive information. There are five basic categories to consider.

 

Audit

Document

Encrypt

Designate

Notify

An enterprise has to know what they have in order to protect it. A complete data audit allows them to determine the exact type of information within their control and establish access levels by individual users, departments, and company-wide. Clear documentation should outline the policies followed for standard compliance regulations in effect, individual access levels, and controls. This written policy builds transparency and makes protocols easier to follow. This category covers the technical aspects of data protection. Data should be encrypted and, when possible, anonymized or pseudonymized. Keys should be tightly controlled and changed regularly to ensure maximum security. Every organization needs a team of responsible people in charge of data protection, along with a named data security officer. This individual should be the top authority for compliance requirements across the entire organization to ensure consistency. Under the GDPR, consumers are entitled to a copy of all personal information collected by companies. There should be a policy in place for these requests. Notification should also cover alert steps for breaches.

 

Most enterprises do a great job of following the above five components of a data protection compliance checklist. However, that’s not quite enough to ensure long-term protection. They need to add a few steps to keep those policies up to date.

 

3 Steps to Add to Remain Compliant

Compliance is complex and not a step-by-step situation. It’s a cycle that requires constant updates and due diligence. The technical steps are just as necessary—if not more so—than written policies and standards. There are three components that every organization should have as part of its data protection compliance checklist.

#1: Consistent follow up

Many organizations reach compliance and never look back. That’s a big mistake, as regulations are ever-evolving. As an example, the GDPR has seen many major updates since its implementation in 2018, and they’re still coming. They’ve updated definitions, protections, and notice requirements that could all impact how an organization approaches compliance. Every other significant data regulation goes through similar states of flux. Leaders should sign up for mailing lists from the agencies that control their rules to ensure they’re up to date.

InSpec is a good platform agnostic tool for checking compliance within the infrastructure of an organization. It can run through servers, containers, and APIs to monitor for issues before they become widespread. This method allows for some level of compliance automation, though it should not be relied on alone. It’s important to incorporate human oversight into the strategy to ensure consistency.

#2: Implement standards through OPA

Open Policy Agent (OPA) is an indispensable compliance tool. It leverages a declarative language, purpose-built for describing policy called Rego to establish controls across the entire system. It essentially turns policy into code that mandates compliance. Combined with application controls to enforce its policy decisions, it can limit where the workload can run, which resources can communicate with others, and user-level permissions. This level of granular control is ideally suited to managing compliance tasks that require attention to detail. Of course, OPA requires proper configuration to ensure the right level of protection. Having an OPA expert on staff will help facilitate the system and make the most of this invaluable tool.

#3: Remediate following a breach

It’s an unfortunate fact that most organizations will deal with a breach at some time or another. In 2020, the US alone saw 1001 data breaches impacting the information of more than 155 million people. While the goal should be to avoid breaches when possible, some reviews must occur when they happen. Specifically, leaders should establish the cause and how it could impact the larger framework. This process shouldn’t be treated as a matter of blame but instead as a learning opportunity that will improve compliance in the future.

No data protection compliance checklist is ever perfect. By treating it as a continuous cycle, organizations can learn and grow their programs as regulations change. With the right tools, it’s possible to automate a large portion of compliance and simplify data protection across the board.