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Data breaches are so common now it hardly breaks through the 24 hour news cycle. Banks, social media sites, law offices and even small, private businesses have all been victims. Overall, the total average cost of data breaches paid by organizations was $6.5 million.
We have written before about the compliance risk from a data breach and how to be prepared. On top of the cybersecurity technology and training, organizations should also be engaging in some established best practices for information governance programs.
An article from JD Supra lays out five of their best practices:
1. Designate a “Privacy Official” and/or Information Security Officer. Put someone in charge. Give them responsibility and authority to get things done, and empower them to speak truth to management. Buy-in from the c-suite and the board of directors is critical to the success of any risk management program. To build and nurture a culture of privacy and security, a responsible party must always be available for questions, complaints and notifications, and a central repository for institutional knowledge regarding privacy and security incidents should be established. By employing “privacy by design” and “security in depth”, you embed information governance in every one of your business processes. Culture is critical.
2. Assessment & Review. How can you protect the crown jewels of your business if you don’t know what and where they are? Truly, information is power. A business’ data is often its most valuable possession. Over 50% of global business assets are intangible assets – information assets – and are thus vulnerable. You must know what you have, where you keep it, how and why you store or transfer it (including to third parties), how you secure it, who needs access to it, when you may no longer keep it, and how you must dispose of it. You cannot protect your data if you do not understand it.
3. Written Policies, Standards & Procedures. Every business needs a “Privacy and Security Package” that includes: an Acceptable Use Policy, an Incident Response Plan, a Disaster Recovery (or Business Continuity) Plan, a Vendor Privacy Agreement, and appropriate Privacy Notices. An Incident Response Plan is paramount: a data breach incident is like a fire or other disaster. If you have not rehearsed what to do, you will move slowly and make errors, when it is most critical for your business to react quickly and effectively. Among its other purposes, the Privacy and Security Package neatly outlines the roles and responsibilities of your management, employees and third parties before, during and after a breach.
4. Employee Training & Education. Perhaps nothing is more important to good Information Governance Program, or is a better value, than privacy and security training of all employees and management. Ultimately, people are any business’ greatest strength (if you have a good program) or greatest weakness (if you do not). Training enables employees to keep up with the cybercriminals, and avoid negligent exposure of sensitive data. It is an integral component of any system of physical, technical and administrative safeguards.
5. Cyber Insurance. Cyber insurance allows a business to shift the risk of a data breach. But carriers want to know that your “risk profile” is appropriate and reasonable. A third-party assessment can provide that comfort level. Coverage is available for businesses of all sizes; however, the terms of coverage are not yet standardized, exclusions are many and varied (and often exclude all expected benefit of the policy), and a “crime endorsement” or “rider” to a general liability policy may sometimes accomplish related, but different, objectives. A competent broker is a must.
These five areas of advice are a solid foundation to build an information governance program around. One word of caution around cyber insurance, however. We wrote a blog post recently exposing the potential for some of those policies to potentially not cover all the associated expenses. Instead, rely on the people, process and information governance technology you have in place to protect your organization.