We need a policy standard for the use of data

One of the issues I'm confronted with in most of the advisories I'm doing is "how to protect information once it leaves a system". A typical situation is that HR data leaves the HR system and is imported in another system - the identity provisioning system, a business analytics tool, or whatever else. Once information is out of HR, it is out of control. Lost somewhere in the happy hunting grounds of information...

However, from a governance perspective (and deu to many specific regulations) we have to keep control. PII has to be well managed, financial data has to be well managed, risk related information as well - and the same is true for many other types of information.

What can we do to address this? The first step is to have a governance process in place for the export/import interfaces. There needs to be a defined process to decide about which information is allowed to be exported for use in other systems. Knowing the paths data can take is an important step; having processes, approvals, and documentation in place definitely helps. Limiting the paths by using fewer systems to distribute information helps as well. You might have 100 interfaces between your HR (or whatever system you are currently looking at) and the target systems or one to a hub, which might be an identity provisioning tool or an ETL platform (Extract, Transform, Load) or something else.

However, these all are limited solutions. They don't solve what happens with data in the target systems. For sure you can expand the processes and policies and try to ensure that the information is handled appropriately in the targets but that is a pretty hard task.

Soem time ago I discussed with Kim Cameron (Microsoft) about protecting PII which a user issues - how can the user keep control over "his" PII? Once he hands this over to a system he is out of control. We might apply techniques derived from IRM (Information Rights Management) to this data; however, that would be a big beast to tame with all the encryption, user management, and policies involved. Kim brought in his idea of using policies which are somewhat "sticky" to the PII and enforced by target systems.

For the foreseeable time this is probably the only approach which will really work, for any type of information flowing: Having a policy standard which defines the rules to use this data. The policy has to flow with the data and it has to be enforced by the target systems. It could include rules covering aspects like the sensitivy of information (PII, financial,...), whether it can be exported again, specific protection requirements, limitations for access ("only users with clearance ..."), and so on. When information out of different sources is combined in a target systems, a resulting policy has to be calculated which again is sticky for that data.

That might sound a little complex but it isn't really that difficult to implement, from my perspective. Is there any chance for success? I think so. Once a standard for such policies is defined and implemented by some of the larger vendors, it will become a decision criteria for information systems: Do they support this standard so that I'm better able to fulfill my governance and compliance requirements? Such a standard will help in achieving data governance and in supporting data owners (and many other players...)

Like with any standard, that requires large vendors to participate and to push the standard. Given that most large vendors are facing these issues, participation should be a no-brainer.

I'm very open to engage in starting such an effort - bringing the participants together, hand over to a standardization initiative, providing my thoughts as initial feeds, and helping in dissemination. Thus when you are interested to particiapte - just send me an eMail. Once I have sufficient initial support I'll try to get the remaining big vendors in.

And, by the way: Don't forget to register for EIC 2011 and Cloud 2011 - early bird will end soon! And maybe we can actively start this initiative there.



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