In May 2017, my fellow KuppingerCole analyst Mike Small published the Executive Brief research document entitled “Six Key Actions to Prepare for GDPR” (then and now free to download). This was published almost exactly one year before the GDPR takes full effect and outlines six simple steps needed to adequately prepare for this regulation. “Simple” here means “simple to describe”, but not necessarily “simple to implement”. However, while time has passed since then, and further regulations and laws are gradually gaining additional importance, properly ensure consumers’ privacy remains a key challenge today.
An even briefer summary of the recommendations provided by Mike is: (1) Find personal data in your organization, (2) control access to it, (3) store and process it legally and fairly, e.g. by obtaining and managing consent. Do (4) all this accordingly in the cloud as well. Prevent a data breach but (5) be properly prepared for what to do should one occur. And finally (6) implement privacy engineering so that IT systems are designed and built from ground up to ensure data privacy.
While tools-support for these steps was not overwhelming back then, things have changed in the meantime. Vendors inside and outside the EU have understood the key role they can play in supporting and guiding their customers on their path to compliance by providing built-in and additional controls in their systems and platforms. Compliance and governance are no longer just ex-post reports and dashboards (although these are still essential for providing adequate evidence). Applications and platforms in daily use now provide actionable tools and services to support privacy, data classification, access control, consent management, and data leakage prevention.
One example: Microsoft’s Office and software platforms continue to be an essential set of applications for almost all organizations, especially in their highly collaborative and cloud-based incarnations with the suffix 365. Just recently, Microsoft announced the availability of a set of additional tools to help organizations implement an information protection strategy with a focus on regulatory and legal requirements (including EU GDPR, ISO 27001, ISO 27018, NIST 800- 53, NIST 800-171, and HIPAA) across the Microsoft 365 platforms.
For data, processes and applications running within their ecosystems, these tools support the implementation of many of the steps described above. By automatically or semi-automatically detecting and classifying personal data relevant to GDPR the process of identifying the storage and processing of this kind of data can be simplified. Data protection across established client platforms as well as on-premises is supported through labeling and access control. This labeling mechanism, together with Azure Information Protection and Microsoft Cloud App Security extends the reach of stronger data protection into the cloud.
An important component on an enterprise level is Compliance Manager, which is available for Azure, Dynamics 365, as well as Office 365 Business and Enterprise customers in public clouds. It enables continuous risk assessment processes across these platforms, deriving individual and specific compliance scores from weighted risk scores and implemented controls and measures.
In your organization’s ongoing journey to achieve and maintain compliance to GDPR as well as for other regulations you need your suppliers to become your partners. In this respect, other vendors have announced the provision of tools and strategies for several other applications, as well as virtualization and infrastructure platforms, ranging from VMware to Oracle and from SAP to Amazon. Leveraging their efforts and tools can greatly improve your strategy towards implementing continuous controls for privacy and security.
So, if you are using platforms that provide such tools and services, you should evaluate their use and benefit to you and your organization. Where appropriate, embed them into your processes and workflows as fundamental building blocks as part of your individual strategy for compliance. There is not a single day to waste, as the clock is ticking.
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