As the focus of mature privacy programs begins to shift from compliance to unlocking value, understanding how using personal data responsibly at all stages of the data lifecycle becomes a business imperative. In this blog series, we have explored the various stages that personal data goes through in the data lifecycle and how it is managed throughout to unlock business upside beyond sole compliance. In part two of the series, we will focus on how to approach responsible data use in the ‘process’, ‘share’, and ‘use’ stages of the data lifecycle as well as looking at the concept of data activation and how this notion is becoming a measurable outcome for privacy teams.
Responsible use in the data lifecycle: Process, share, and use
Processing, sharing, and using personal data make up the three stages of the data lifecycle that require the most attention from both a compliance and a business upside perspective. When looking at the ‘process’ stage, data mapping must mature from static documentation to comprehensive, evergreen records of your processing activities. The ‘share’ stage requires you to take a closer look at your third-party management and how vendor risk is managed. In the ‘use’ stage, your focus should turn to governance and data controls to ensure your organization is using data responsibly and in line with applicable regulations. When you look at these three stages in the wider context of the data lifecycle, data activation starts to become an important component for unlocking business value from responsible data use within mature privacy programs.
Data mapping as the foundation for responsible data use
The foundation that responsible data use is built upon comes from a robust data and activity map. In early-stage data privacy programs, this typically looks like a static document - often spreadsheet-based - that only documents limited information about your processing activities. However, these static documents are often incomplete and are difficult to maintain as businesses increase the volume of their data activities and the regulatory landscape evolves. As we look through the lens of responsible use, and you look to mature your privacy operations, there is a growing need for a real-time view of data processing to ensure it remains consistent with its original purpose and that it meets applicable regulatory requirements. Having a comprehensive, evergreen data map can begin to act as a foundation for responsibly sharing personal data with third parties and developing appropriate access controls to promote responsible data use across your organization.
Ensure responsible sharing of data through third-party risk management
Regardless of privacy program maturity, organizations increasingly rely on sharing personal data with third parties to drive revenue. However, ensuring that third parties meet sufficient privacy and security standards requires robust processes to assess the risk they pose and to monitor this risk over time. To begin building responsible data use into the ‘share’ stage of the data lifecycle you must first look at your risk assessment processes. Typically, in early-stage privacy programs, risk assessments will lack consistency and tend to be performed on an ad-hoc basis. But as your program matures with structured frameworks and greater collaboration, this will allow you to start embedding the results of risk assessments into your business decision-making. Implementing a “shift-left” approach to risk management – where certain processes are moved to the outset of a project - will help inform the product development process of potential risks so that the appropriate safeguards can be built into the very fabric of the product.
Access controls offer greater governance and security for data use
Organizations at the upper end of the maturity scale will likely be turning their attention to data governance and access controls to begin unlocking business value from personal data through its responsible use. Appropriate access controls help to make sure that the availability of personal data held by your organization is limited to only those who need access but also means that personal data is available to be used – i.e. the conditions for its use are aligned to regulatory requirements - to deliver more personalized experiences and to innovate with new products and services. Additionally, access controls help to keep data secure by minimizing the risk of unauthorized access and creating visibility into violations of access policies to ensure appropriate remediation can be deployed.
Data activation and the expanded role of the privacy professional
You might be asking, what is data activation and why does it matter to me? Data activation is the process of taking the data your company collects and actively using it to improve business outcomes, rather than just merely storing it. From a privacy perspective, this means ensuring that the appropriate controls are applied so that data can be used responsibly, and that data usage is in line with applicable regulatory requirements. Where traditional data activation has been an initiative for marketing teams that involves turning raw data into insights, decisions, and actions, it now requires privacy teams to balance this strategic data utilization with the safeguarding of personal information. In doing so, data activation becomes a crucial measurable outcome of the privacy program.
Therefore, the role of the privacy professional is now at an inflection point, evolving from gatekeepers to strategic enablers. With data activation responsibilities, the focus is shifting to balance privacy risks with the value derived from data use. In turn, privacy professionals are becoming increasingly integral to the product design process, ensuring privacy by design principles are embedded from the outset. Expertise in legal compliance is evolving to include an understanding of data science and analytics in order to appropriately build data usage policies that foster innovation while safeguarding personal information. Continuous education on technological advances will be crucial to adapt to this new dynamic role and foster cross-functional collaboration to maintain an agile approach to new regulations.
Data Privacy Maturity Model and how OneTrust helps
Building mature processes into your data privacy program can feel overwhelming without a robust framework to work against. The OneTrust Data Privacy Maturity Model has been developed to help you understand the current state of your privacy program and highlight the steps necessary to mature your processes from meeting compliance requirements to driving business value. By using the Data Privacy Maturity Model, you can map your data privacy program against four stages of maturity and understand the parts of program evolution from data mapping to customer preferences and AI governance that start to drive business value beyond compliance.
Take the Data Privacy Maturity Model self-assessment to discover the steps you can take to mature your data privacy program.
