Psst… stop staring into the tool bag and look around you.
IT security and privacy pros who are tasked with helping their companies come into compliance with the European Union's General Data Protection Regulation (GDPR) would be better served rounding up a cross-section of co-workers and executives than throwing all efforts toward buying more IT products, a recent Forrester Research report found.
Although security controls, such as encryption, tokenization and the use of network security tools, are a top priority for a number of organizations seeking to achieve GDPR compliance, Forrester finds these strategies rely too heavily on IT for answers.
For many InfoSec pros, however, that is their comfort zone and may contribute to the challenges they may face in GDPR compliance.
"We know that GDPR investments usually come from IT budgets … but encryption is really the only security control that is called out specifically in the GDPR," Enza Iannopollo, an analyst on Forrester's Security & Risk team and co-author of the report, told Security Now.
Because of these heavy IT investments, as well as an approach by security and privacy pros to tackle GDPR requirements individually, companies are missing out on developing a meaningful comprehensive compliance program, she notes.
"They need to approach this as privacy-by-design," Iannopollo said. "You need to bring people together from across the organization to collaborate on ways to protect the information."
This means adopting processes and procedures to allow the continuous collaboration from DevOps teams to business units, from data scientists to security and privacy peers, the report notes.
Without a privacy-by-design process, problems in meeting and maintaining GDPR compliance may result, Iannopollo warns.
Problems without processes in place
"The roadblock that I come across the most is the ability of companies to identify and manage risk," Iannopollo said, pointing to a lack of executive ownership in the GDPR compliance process and the vacuum it creates in tackling the problem.
Customer notification after a breach is another problem area that may arise without a process in place.
Although a majority of organizations feel prepared to notify the data protection authorities within 72 hours after a breach, as required under the GDPR, companies are neglecting to train and test their ability to notify customers within the same timeframe as required by the GDPR, Forrester cites in its report.
Security and privacy pros also need to shift their mindset from satisfying individual GDPR requirements to developing a process of creating, executing and documenting a comprehensive GDPR compliance strategy, according to Forrester.
This is imperative given GDPR regulators have the ability to potentially audit firms on a continuous basis, which means a comprehensive and continuous GDPR compliance strategy is needed, Iannopollo notes.
Is your company GDPR ready?
The report found nearly 30% of the 3,752 survey respondents from around the globe believed their organization was fully GDPR compliant.
However, Forrester notes that based on its own research, most companies are taking a "piecemeal" approach and meeting only specific compliance requirements, such as encryption or data breach notification, and considering themselves in full compliance.
The survey also found some industries are further along in GDPR compliance than others. Highly regulated fields, such as the financial services industry, tend to have established teams of compliance and data protection workers, as well as data protection officers (DPO) on board.
The retail and media industries, meanwhile, are just now beginning to ramp up their GDPR compliance efforts, Forrester reports, despite both sectors possessing a treasure trove of customers' personal data.
Creating a comprehensive GDPR compliance framework
The report points to three areas that companies should consider when developing their compliance framework:
- Execute GDPR programs across systems, processes, people and governance.
- Involve all appropriate teams from day one.
- Invest in compliance management solutions to support continuous GDPR compliance.
"GDPR is a cross-functional effort," Iannopollo said.
— Dawn Kawamoto is an award-winning technology and business journalist, whose work has appeared in CNET's News.com, Dark Reading, TheStreet.com, AOL's DailyFinance and The Motley Fool.