As the privacy landscape continues to evolve, key focus areas of privacy program management are shifting. A product of such an evolving landscape is that privacy teams must implement programs tailored to both regulations (e.g. Schrems II, GDPR, CCPA & CPRA, LGPD , etc.) and the intricacies of cross-border data transfer. With so much for teams to consider, enterprises must showcase both legal and customer credibility, which starts by implementing a healthy privacy management program. When implementing a privacy management program, it’s important to consider the role that Vendor Risk Management plays in the overall privacy sphere.
Successful third-party attacks have increased rapidly over the last year, exposing new vulnerabilities for bad actors to exploit in the process. Perfect examples of this are the recent SolarWinds attack, increased ransomware incidents, and the Pipeline Attack. Each of these events has placed an emphasis on not only the importance of maintaining a strong security posture, which includes addressing all aspects of organizational cybersecurity from both the bottom-up and top-down but also called out Vendor Risk Management (VRM) as a key focus area for C-suite members and security teams alike. Here we explore the relationship between the top-down cybersecurity structure and VRM starting with one role: the Chief Privacy Officer (CPO).
Explore the importance of vendor risk management: The Ultimate Guide to Vendor Risk Management
The chief privacy officer & vendor risk management
When analyzing security posture from a top-down lens, it’s important to understand the role that the Chief Privacy Officer plays. CPOs have a specific risk domain that they care about: privacy. With the shift to the cloud, increased attacks, and the rapid shift to remote work structures, more organizations are sharing sensitive data with vendors, making VRM a critical component of privacy posture for CPOs to focus on.
Understanding the vendors that you work with and how you work with them is critical to any privacy program. However, as more and more business initiatives are outsourced to the cloud, it can be difficult to understand where personal data is going and how it is being managed. Chief Privacy Officers need visibility into their vendor inventory so they can better map data flows and ensure personal data is not being given to vendors without the consent of the individual.
CPO challenges
As VRM’s criticality increases, it’s important to prioritize vendor risk management despite the challenges that come with taking on such a substantial task. CPOs need to consider a vast array of frameworks and regulations, including Schrems II, GDPR, CCPA & CPRA, LGPD , etc. The number of regulations is astronomical and only continues to grow as digital transformation pushes for more stringent protection of data subject rights. Many regulations have brought vendor management into the forefront for privacy professionals, but it has been, and remains, a challenge for compliance. With increasing concerns around ethical third-party data usage, third-party data breaches, and future attacks on the horizon, VRM remains a top concern for CPOs focused on enabling their organization to protect personal data.
Each of these challenges directly correlates to the rapid expansion of an organization’s vendor ecosystem and works hand-in-hand to increase the risks that privacy teams must consider when analyzing their security posture as related to vendor risk management.
Learn more about managing vendor risk in our webinar: Expert Panel: How Do You Manage Vendor Risk?
Solutions & best practices
Enabling yourself, your team, and employees across all levels of your enterprise to understand vendor-associated risk is imperative in establishing strong privacy structures within your vendor risk management program. When combating challenges rooted in rapid technological expansion, increased quantity of frameworks and regulations, and safe data storage, it’s crucial the CPO asks the right questions. Here are the 6 key questions we suggest asking to prioritize privacy in all aspects of your supply chain:
- Who are they working with?
- What business processes are associated with which vendors?
- What personal data do these vendors have access to?
- What safeguards do vendors have in place to protect personal data?
- Where is data going (cross-border transfers)?
The ideal outcome is that CPOs can understand data transfers with greater clarity and have a continual working knowledge of the role that vendors play in privacy across the organization.
How can OneTrust help?
The OneTrust platform leverages expertise in Vendor Risk Management, Privacy, GRC, and many other categories to deliver an immersive privacy management experience. We enable you to gain visibility into all aspects of your organization’s security structure by building your VRM program from the ground up, giving you a vendor inventory, and enabling your team to link your vendors to data maps and business processes to understand data flows.
Specifically, OneTrust Vendorpedia will allow you to build out details on vendors to include attributes specific to privacy regulations, conduct PIAs and other assessments on your vendors, and automate your vendor lifecycle from onboarding to offboarding. Learn more today.
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