Webinar | Metrics for Success: Quantifying the Value of the Privacy Function

Metrics for Success: Quantifying the Value of the Privacy Function December 8, 2016

Privacy Insight Series - truste.com/insightseries v

v

© TRUSTe Inc., 2016 1 © TRUSTe Inc., 2016

Today’s Speakers Deidre Rodriguez Director, Corporate Privacy Office Anthem, Inc

Marcus Morissette Global Privacy Officer eBay

Kevin Trilli, SVP Product, TRUSTe

Privacy Insight Series - truste.com/insightseries v

2 © TRUSTe Inc., 2016

Privacy Metrics and Dashboard Kevin Trilli, SVP Product, TRUSTe

Privacy Insight Series - truste.com/insightseries v

v

© TRUSTe Inc., 2016 3 © TRUSTe Inc., 2016

Agenda

• Speaker Intros • Metrics and Privacy Organization • Categories and types of Metrics • Building / establishing a Monitoring Program • Challenges and Recommendations

Privacy Insight Series - truste.com/insightseries v

4 © TRUSTe Inc., 2016

Privacy Metrics

Privacy Insight Series - truste.com/insightseries v

v

© TRUSTe Inc., 2016 5 © TRUSTe Inc., 2016

Purposes and Categories of Metrics

Target Audience

Audience

Purpose

Privacy Officer / Privacy Manager

Internal

• Program development • Organizational Management

Executives / BOD

Internal

• Communicate overall risk posture • Resource requests

Auditors / Regulators

External

• Demonstrate program accountability and effectiveness • Transparency

Privacy Insight Series - truste.com/insightseries v

6 © TRUSTe Inc., 2016

CPO/Privacy Manager: Program Establishment, Evolution and Budgeting

• Initial stage is strategy planning and development – Requires selecting and planning a set of program activities – Establish required set of resources

• On-going management – Program and goal management – Resource utilization – Gaps / program maturity velocity

Privacy Insight Series - truste.com/insightseries v

7 © TRUSTe Inc., 2016

Example: Privacy Program Management

Privacy Insight Series - truste.com/insightseries v

8 Š TRUSTe Inc., 2016

CPO/Privacy Manager: Operational Management • Inbound inquiries to privacy team (tickets/advise/projects) – % utilization

• Policies under management –Reflective of external and internal laws, regs, policies  shows scope

• Assets under management – Data processing applications and systems

• Projects (risk assessments, PIAs, etc) – #, state, aging, response time

– risk issues identified and remediated

• Incidents (breach, data release, reg inquiries) – #, type and risk levels, remediation plan

• All are mapped to each BU to show status across enterprise –Includes HR, IT and Marketing functional groups as needed Privacy Insight Series - truste.com/insightseries v

9 © TRUSTe Inc., 2016

Example: Risk Assessment and Remediation Metrics

Privacy Insight Series - truste.com/insightseries v

10 Š TRUSTe Inc., 2016

Executive / BOD

• Privacy Program Overview / Budgeting – Program to Goal (%) – Overall Resource allocation – Budget justification

• Risks – Incidents – Regulatory enquiries

– Related fines/investigations (vertical) – Heat Map

Privacy Insight Series - truste.com/insightseries v

11 © TRUSTe Inc., 2016

External Reporting • Derived from internal metrics/dashboard, but may need sanitizing • Have ready on-demand to demonstrate program – Ideal: Technological system of record that can grow and aggregate project/project – Maintained for data integrity

• Basics: – Database of data processing assets (#, classified by risk) with metadata – Construction of key data transfers (EU, APEC)

– Consumer metrics (inquiries/disputes and resolution paths)

• Needs to accompanied by evidence/documentation

Privacy Insight Series - truste.com/insightseries v

12 © TRUSTe Inc., 2016

Example: Asset Inventory characterized by risk

Privacy Insight Series - truste.com/insightseries v

13 Š TRUSTe Inc., 2016

Where to Start

Privacy Insight Series - truste.com/insightseries v

v

© TRUSTe Inc., 2016 14 © TRUSTe Inc., 2016

Starting a Monitoring Program • First socialize with stakeholders / execs • Determine what matters most / scope • Prioritize to get started • Assess current capabilities

Privacy Insight Series - truste.com/insightseries v

15 © TRUSTe Inc., 2016

Starting a Monitoring Program •Document your privacy program plan to get ready –Will you need to develop emails or templates for use during monitoring (announcement emails, SharePoint sites created, who will be responsible for what) –Determine where you will store data and who will have access

–Are there callouts/disclaimers that need to added to metrics?

–When will metrics be produced and by whom –Stagger monitoring so that it will not create negative impact for the business –Understand any reporting/monitoring that may be done in the business that will have potential impact –Write desktop procedure for how everything will happen A-Z

• Communicate across broader organization

Privacy Insight Series - truste.com/insightseries v

16 © TRUSTe Inc., 2016

Beginning to Monitor

Privacy Insight Series - truste.com/insightseries v

v

© TRUSTe Inc., 2016 17 © TRUSTe Inc., 2016

Beginning to Monitor •Identify lead that will be responsible for monitoring a specific piece of work •Put everything on the calendar –Date you will start sending requests to business –Date you will analyze data –Date that you will document findings –Date you will review metrics –Date that you will release metrics –Date corrective action plans will be due –Any ongoing follow up or re-monitoring to ensure issue has been adequately addressed

•Keep leadership informed of roll out and any changes to program that may impact them

Privacy Insight Series - truste.com/insightseries v

18 © TRUSTe Inc., 2016

Continuing to Grow Monitoring Program

Privacy Insight Series - truste.com/insightseries v

v

© TRUSTe Inc., 2016 19 © TRUSTe Inc., 2016

Growing Monitoring Program •Continue to monitor risks and what matters most •Identify plan to grow program –What will be monitored next and why –Doing it by risk is easiest to explain –Continue to lobby for resources to expand program

•Continue to collect feedback on metrics •Document all findings and do follow up on corrective action plans –This enables you to show leadership the positive impact of your program (what were you able to find and correct)

•Partner with Internal Audit •Roll up data by quarter and produce annual metrics

Privacy Insight Series - truste.com/insightseries v

20 © TRUSTe Inc., 2016

Challenges and Takeaways

Privacy Insight Series - truste.com/insightseries v

v

© TRUSTe Inc., 2016 21 © TRUSTe Inc., 2016

Challenges

• How to do actual job but also measure and document • Control of data sources that feed metrics • Dealing with aspects of privacy management that don’t have easy metrics

Privacy Insight Series - truste.com/insightseries v

22 © TRUSTe Inc., 2016

Contacts Deidre Rodrigeuz Marcus Morissette Kevin Trilli

Privacy Insight Series - truste.com/insightseries v

Deidre.Rodriguez@anthem.com mmorissette@ebay.com ktrilli@truste.com

v

Š TRUSTe Inc., 2016 23 Š TRUSTe Inc., 2016

Thank You! Details of our 2017 Winter/Spring Webinar Series will be available shortly.

See http://www.truste.com/insightseries for all the 2016 Privacy Insight Series and past webinar recordings.

Privacy Insight Series - truste.com/insightseries v

v

Š TRUSTe Inc., 2016 24 Š TRUSTe Inc., 2016