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66 Posts authored by: Marshall Toburen Employee

Last year about this time, I reported that Gartner had named Dell / RSA Archer a Leader in its inaugural Magic Quadrant for Integrated Risk Management. It has happened again! For the second consecutive year, Gartner positioned Dell Technologies (RSA) as a Leader in its 2019 Magic Quadrant for Integrated Risk Management Solutions. We believe this positioning speaks to the strengths of the RSA Archer® Suite in addressing today’s complex and fast-moving digital risks.

 

Gart

 A Big Thank You to Our Customers!

Participation in these analyst evaluations requires a significant commitment of time and resources, and we could not have achieved this Leader position without the support of our customers acting as references in Gartner’s evaluation. Our sincere thanks to all of you that have acted as a reference on our behalf.

 

I look forward to seeing you all at RSA Charge in September to celebrate in person!

 

Magic Quadrant for Integrated Risk Management; Published: 15 July 2019; Analyst(s):Brian Reed,  Jie Zhang

This graphic was published by Gartner, Inc. as part of a larger research document and should be evaluated in the context of the entire document.
 

Gartner does not endorse any vendor, product or service depicted in its research publications, and does not advise technology users to select only those vendors with the highest ratings or other designation. Gartner research publications consist of the opinions of Gartner's research organization and should not be construed as statements of fact. Gartner disclaims all warranties, expressed or implied, with respect to this research, including any warranties of merchantability or fitness for a particular purpose.

What is Operational Risk?

The Risk Management Association defines operational risk as “the risk of loss resulting from inadequate or failed internal processes, people, and systems, or from external events.” Sources of operational risk include natural and man-made disasters, cyber-attacks, errors, fraud, and regulatory or contractual non-compliance.

 

Why is the proper management of Risk so important?

In addition to operational risk, organizations today face a wide range of risks originating in different areas of their business, including risk to achieving strategies and objectives, credit risk, interest rate, liquidity, and market risk, political risk, and reputation risk, to name a few.  Many of these risks arise within the four walls of the organization and many are inherited through the extended third-party ecosystem that the organization engages. 

 

As an organization grows in size and complexity, converts to digital, moves into new markets, introduces new, more sophisticated or novel products and services, is subject to more regulatory obligations, extends its third party dependencies, or is exposed to political, social, or environmental challenges, it becomes much more difficult for the organization’s management and board of directors to understand and manage its risks.  Without a clear understanding of their risks, these organizations tend to experience more surprises and losses, and have a more difficult time achieving their objectives and strategies.  Some of these risks may threaten the very existence of the organization, or the livelihood of its managers and board of directors.  Consequently, these risks must be effectively identified, assessed, and managed to protect the organization’s leadership and ensure the organization can meet its objectives.

 

RSA Archer Risk Catalog

RSA Archer Risk Catalog provides the foundation to record and track risks across your enterprise, and establish accountability by named first and second line of defense managers. It provides a three-level roll-up of risk, from a granular level up through enterprise risk statements. Inherent and residual risk can be assessed utilizing a top-down, qualitative approach, with assessed values rolling up to intermediate and enterprise risk statements.

 

Key features include:

  • Consistent approach to documenting risk, assigning accountability, and assessing risks
  • Oversight and management of all risks in one central location
  • Ability to understand granular risks that are driving enterprise risk statements
  • Consolidated list of prioritized risk statements

 

RSA Archer Risk Catalog enables organizations to:

  • Obtain a consolidated list of the organization’s risk
  • Enforce a consistent approach to risk assessments
  • Prioritize risks to make informed decisions about risk treatment plans
  • Create accountability for the ownership and management of risk

 

The RSA Archer Risk Catalog is an essential use case of the RSA Archer Ignition Program, designed to empower organizations of all sizes to respond to risk with data-driven facts using a streamlined, fast time-to-value approach

 

Today, organizations are faced with complex and fast moving challenges.  RSA Archer Risk Catalog is one element of an effective Integrated Risk Management program.  Stressing the agility and flexibility needed by today’s modern organizations, integrated risk management brings together the various domains of risk across business activities (horizontally), connecting the activities to the strategies and objectives of the organization on an aggregated basis (vertically). This approach to risk management provides leaders with the most holistic understanding of risk facing their organization so they can make truly informed decisions about where to deploy limited capital and human resources to produce optimized returns for the organization while maximizing the likelihood of achieving the organization’s objectives.

 

As your organization grows and changes, your risk management program must evolve and manage risk more holistically, with more agility and integration than before. Effective risk management is essential for improving an organization’s risk profile.  RSA Archer can help your organization better understand and manage its risk on one configurable, integrated software platform. With RSA Archer solutions, organizations can efficiently implement risk management processes using industry standards and best practices and significantly improve their business risk management maturity.

 

For more information, visit RSA.com or read the Datasheet.

 

What is Operational Risk?

The Risk Management Association defines operational risk as “the risk of loss resulting from inadequate or failed internal processes, people, and systems, or from external events.” Sources of operational risk include natural and man-made disasters, cyber-attacks, errors, fraud, and regulatory or contractual non-compliance.

 

Why is Operational Risk Management so important?

For many organizations, effective operational risk management is inherently complex. As organizations grow in size and complexity, convert to digital, move into new markets, introduce new, more sophisticated or novel products and services, becomes subject to more regulatory obligations, or extends its third party dependencies, it becomes much more difficult for the organization’s management and board of directors to understand and manage its risks.  Without a clear understanding of their risks, these organizations tend to experience more surprises and losses, and have a more difficult time achieving their objectives and strategies.  Some operational risks may threaten the very existence of the organization, or the livelihood of its managers and board members.  Consequently, these risks must be effectively identified, assessed, and managed by business unit leaders (the first line of defense) and executive management to adequately protect the organization’s leadership and ensure the organization can meet its objectives.

 

Without engaging the first line of defense in identifying risk, and using consistent methodologies and measurements to assess risk, there is no way to provide executive management and the Board with an accurate and aggregated view of risk across the business.  Good operational risk management protects the organization from operational losses and surprises.

 

RSA Archer Operational Risk Management

RSA Archer Operational Risk Management is a combination of use cases that are core to a typical operational risk management program. These elements include: Top-Down Risk Assessment, Bottom-Up Risk Assessment, Loss Event Management, Key Indicator Management, Risk and Control Self-Assessments, Issues Management, and Scenario Analysis. RSA Archer Operational Risk Management enables cataloging business processes and sub-processes, documenting risks associated with business processes, and  control procedures. Risk self-assessments can be performed on a top-down basis, through first line of defense self-assessments, and through targeted bottom-up assessments. Loss events can be cataloged, root-cause analysis performed and routed for review and approval. Key risk and control indicators can be established and associated with risk and control registers, respectively, and monitored to provide early warning of changes in the organization’s risk profile. By integrating these use cases, risk managers have a comprehensive operational risk management program that reinforces desired accountability and risk management culture throughout the organization, providing necessary transparency through reporting, dashboards, and notification alerts.

 

Key features include:

  • Consolidated view into business processes, risks, controls, loss events, key indicators, and outstanding issues; an understanding of how they are all related; and accountability for each
  • Support for first line of defense self-assessments, and top down and bottom up risk assessments
  • Efficient management of self-assessment campaigns by second line of defense stakeholders, including necessary workflow to vet and challenge first line of defense assessments
  • Capture and perform root cause analysis on internal losses and near misses, and relevant external loss events, routing loss events to stakeholders for review and approval consistent with delegated authorities and loss type.
  • Enforce consistency in creation of risk and control registers through the use of risk and control libraries
  • Catalogue risk scenarios and capture and perform scenario risk assessments
  • Understand inherent and residual risk and observe changes in calculated residual risk while rolling up risks by business unit and enterprise risk statement
  • Robust key risk and control indicator program management to provide early warning and remediation
  • Consolidated issues management with a clear understanding at all times of the status of all open remediation plans and exceptions
  • Visibility into operational risk via predefined reports, risk dashboards, workflow, and notifications
  • Perform risk assessments qualitatively, quantitatively using monetary values, and support Monte Carlo simulation based on expert elicitation and loss events.

 

RSA Archer Operational Risk Management enables:

  • Better understanding of risks and controls throughout the organization
  • Improved risk management and risk management culture by engaging the first line of defense (business users) to take ownership of their risks and controls
  • Quicker detection and management of changes in risk profile
  • More efficient administration of the operational risk management program, allowing second line of defense teams to spend more time on analysis and less time on administration and reporting
  • Less time required to identify and resolve operational risk-related problems
  • Reduction in audit findings, surprises, loss events, and incidents,
  • Ability to clearly demonstrate the design and effectiveness of your organization’s risk management program

 

Today, organizations are faced with complex and fast moving challenges.  RSA Archer Operational Risk Management addresses the core requirements of an effective Integrated Risk Management program.  Stressing the agility and flexibility needed by today’s modern organizations, integrated risk management brings together the various domains of risk across business activities (horizontally), connecting the activities to the strategies and objectives of the organization on an aggregated basis (vertically). This approach to risk management provides leaders with the most holistic understanding of risk facing their organization so they can make truly informed decisions about where to deploy limited capital and human resources to produce optimized returns for the organization while maximizing the likelihood of achieving the organization’s objectives.

As your organization drives business growth through an extended ecosystem strategy, your risk management program must evolve and manage risk more holistically, with more agility and integration than before. Effective risk management is essential for improving an organization’s risk profile.  RSA Archer can help your organization better understand and manage its risk on one configurable, integrated software platform. With RSA Archer solutions, organizations can efficiently implement risk management processes using industry standards and best practices and significantly improve their business risk management maturity.

 

For more information, visit RSA.com or read the Datasheet.

 

What is Operational Risk?

The Risk Management Association defines operational risk as “the risk of loss resulting from inadequate or failed internal processes, people, and systems, or from external events.” Examples of operational risk include natural and man-made disasters, cyber-attacks, errors, fraud, and regulatory or contractual non-compliance.

 

Why is Bottom-Up Risk Assessment so important?

The introduction of new products and services, mergers and acquisitions, business process changes, and fraud are often viewed as risk projects to be evaluated when making decisions to move forward or enhance risk treatments. All too often, these kinds of operational project reviews are performed on an ad-hoc basis, using an unstructured and inconsistent approach. Bottom-up, project-oriented risk assessments are prone to incomplete and unreliable information. In addition, IT and business teams are often asked to collect the same assessment data via spreadsheets, Word documents, and email for different risk and compliance assessments. This manual approach results in missed project deadlines,  inconsistent and inaccurate risk assessments, risk treatments, and remediation plans. Manual approaches also often inefficient and expensive, and lack an easy way to compare results of multiple assessments. Since risks cannot be identified or assessed properly, losses, incidents, or other surprises related to the project may arise at a later date. Without visibility to or accountability in addressing known risks identified through bottom-up risk assessments, resource misallocation and slow implementation in risk treatment are the typical results.

 

RSA Archer Bottom-Up Risk Assessment

RSA Archer Bottom-Up Risk Assessment allows you to engage your teams via targeted project risk assessments. Projects can include such things as new and changing business processes, fraud assessments, new products and services, and proposed mergers, acquisitions, and divestitures.  Projects can be documented and questionnaires can be created with custom questions, as well as questions derived from RSA Archer’s extensive library of thousands of out-of-the-box questions. When risks are deemed too high, risk treatments and remediation plans can be documented and tracked through to resolution and approval.

 

Key features include:

  • Consistent approach to identify and assess project-related risk
  • Oversight and management of all risk assessments in process
  • Risk treatment plans are known across all assessments and implementation plans can be monitored to completion
  • Consolidated list of prioritized risk treatments and remediation plans
  • Visibility into assessment progress, risk treatments and remediation activity via pre-defined reports and risk dashboards
  • Named accountability for assessments and remediation plans

 

RSA Archer Bottom-Up Risk Assessment provides:

  • Consistent approach to identify and assess project-related risk
  • Oversight and management of all risk assessments in process
  • Known risk treatment plans across all assessments and implementation plans that can be monitored to completion
  • Consolidated list of prioritized risk treatments and remediation plans
  • Visibility into assessment progress, risk treatments and remediation activity via pre-defined reports and risk dashboards
  • Accountability for risk assessment and remediation activities

 

Today, organizations are faced with complex and fast moving operational risk challenges.  Tracking changing business activities is a core best practice in Operational Risk Management.  RSA Archer Bottom-Up Risk Assessment is a key element of an effective Operational and Integrated Risk Management program to assess risk associated with changing business activities.  Stressing the agility and flexibility needed by today’s modern organizations, integrated risk management brings together the various domains of risk across business activities (horizontally), connecting the activities to the strategies and objectives of the organization on an aggregated basis (vertically). This approach to risk management provides leaders with the most holistic understanding of risk facing their organization so they can make truly informed decisions about where to deploy limited capital and human resources to produce optimized returns for the organization while maximizing the likelihood of achieving the organization’s objectives.

 

As your organization drives business growth, your risk management program must evolve and manage risk more holistically, with more agility and integration than before. Effectively performing Bottom-Up risk assessments is one ingredient to demonstrating real progress and improvement in decreasing business risk.  RSA Archer can help your organization better understand and manage risk assessments on one configurable, integrated software platform. With RSA Archer solutions, organizations can efficiently implement risk management processes using industry standards and best practices and significantly improve their business risk management maturity.

 

For more information, visit RSA.com or read the Datasheet.

 

 

 

What is Operational Risk?

The Risk Management Association defines operational risk as “the risk of loss resulting from inadequate or failed internal processes, people, and systems, or from external events.” Examples of operational risk include natural and man-made disasters, cyber-attacks, errors, fraud, and regulatory or contractual non-compliance.

 

Why is Key Indicator Management so important?

The use of key indicators of performance, risk, and control are considered one of several best practices of a sound Operational Risk Management program.  In many risk management programs, the use of key indicators is implemented sporadically at the discretion of individual business units and division managers. Key indicator metrics may not be properly designed to accurately measure the intended activity, and the collection of indicator data may be accomplished in an unnecessarily costly and inefficient manner using spreadsheets and email. With missing or inefficient key indicator reporting, the organization is unable to accurately gauge or compare performance in terms of meeting strategic and operational goals, or understand drivers of risk and control. It also limits the organization’s ability to respond to emerging problems as quickly as possible.

 

RSA Archer Key Indicator Management

RSA Archer Key Indicator Management provides a means for organizations to establish and monitor metrics related to each business unit and activity within the organization.  Key indicators are also typically associated with other elements of your governance program, including risks, controls, strategies and objectives, products and services, and business processes to monitor quality assurance and performance.

 

Key features include:

  • Holistic key indicator management program
  • Association of key indicators with business units and named individuals, and establishment of key indicators of performance, risk, control, corporate objectives, business processes, and products and services, depending on your program implementation
  • Utilization of key indicator libraries to ensure consistency and quick deployment throughout the organization
  • Governance to ensure timely collection of indicator data
  • Stakeholder notification when indicators exceed acceptable boundaries
  • Consistent approach to calculating indicator boundaries and limits
  • Consolidated list of indicators that are operating outside boundaries, and associated stakeholder escalation and remediation plans
  • Accountability and management processes around remediation plans and action to bring key indicators back within acceptable boundaries
  • Visibility to key risk indicator metrics and remediation plans via predefined reports, dashboards, workflow, and communication channels.

 

Today, organizations are faced with complex and fast moving operational risk challenges.  To effectively manage risk, it’s not enough to know your organization’s strategies, objectives, risks and controls.  You need a way to understand if your strategies and objectives are being met; if your risk drivers are increasing or decreasing; and whether your controls are operating as designed or are under stress leading to failure. Tracking your key indicators, the Performance, Risk, and Control indicators associated with each of these elements is crucial in successful organizations today.  In addition, indicators associated with changing business activities are a good early warning of changing risk and performance profile. 

 

RSA Archer Key Indicator Management is an essential element of an effective Operational and Integrated Risk Management program to understand the organization’s risk and performance profile and operation of the existing internal control framework.  Stressing the agility and flexibility needed by today’s modern organizations, integrated risk management brings together the various domains of risk across business activities (horizontally), connecting the activities to the strategies and objectives of the organization on an aggregated basis (vertically), including these key indicators. This approach to risk management provides leaders with the most holistic understanding of risk facing their organization so they can make truly informed decisions, as quickly as possible, about where to deploy limited capital and human resources to produce optimized returns for the organization while maximizing the likelihood of achieving the organization’s objectives.

 

As your organization drives business growth, your risk management program must evolve and manage risk more holistically, with more agility and integration than before. Effectively deploying and utilizing Key Indicator management is one ingredient to demonstrating real progress and improvement in decreasing business risk.  RSA Archer can help your organization better understand and manage key indicators on one configurable, integrated software platform. With RSA Archer solutions, organizations can efficiently implement risk management processes using industry standards and best practices and significantly improve their business risk management maturity.

 

For more information, visit RSA.com or read the Datasheet.

 

 

 

What is Operational Risk?

The Risk Management Association defines operational risk as “the risk of loss resulting from inadequate or failed internal processes, people, and systems, or from external events.” Examples of operational risk include natural and man-made disasters, cyber-attacks, error, fraud, and non-compliance.

 

Why is Loss Event Management so important?

Loss events negatively impact an organization’s income statement.  Under certain circumstances they can be large enough to wipe out current period profitability, erode an organization’s capital cushion, or even force it into bankruptcy.  Consequently, it is critically important for organizations to understand the kinds of losses it could incur, the near-miss losses it avoided, and the losses it actually incurred.  This means understanding how and why a loss arose, what policies were not followed, what controls failed, where the loss is or should be recovered under insurance, and what should be done to reduce the likelihood and impact of similar losses occurring in the future.

 

Understanding and managing loss events is essential to an effective operational risk management program. Many organizations today have impaired visibility into the frequency, amount, type and source of loss events. This is frequently due to lack of complete or comprehensive lists of loss events, lack of accountability for management of loss events, and inadequate root cause analysis. These organizations are not fully aware of their actual losses, nor are they aware of near misses or losses being incurred by others in their industry that may warn of the organization’s own future losses. Lack of accountability promotes a less effective risk management culture, and these organizations typically suffer from a higher frequency and amount of loss events due to poor loss event analysis and remediation.

 

RSA Archer Loss Event Management

RSA Archer® Loss Event Management allows organizations to capture and inventory actual loss events and near misses, as well as relevant external industry-related loss events. Loss event root cause analysis can be performed to understand why the loss occurred and to take appropriate actions to reduce the likelihood and impact of similar losses occurring in the future. Loss events can be evaluated as part of top-down risk assessments and risk self-assessments, if those are utilized, and loss events can be exported to perform Monte Carlo simulations of operational risk using external Monte Carlo engines, such as Palisade @Risk.  Recoverable losses can be monitored and managed until they are reimbursed through insurance or restitution agreements.

 

Key features include:

  • Consolidated loss event catalog including actual losses, near misses, and calibrated external loss events
  • Assignment of loss events by business unit and named individuals
  • Root cause analysis
  • Review and approval of loss events by key stakeholders within their levels of authority
  • Visibility into aggregate losses by type, source, and area of ownership
  • Ability to drill into specific loss events for greater detail
  • Consolidated list of remediation plans to reduce likelihood and impact of similar future loss events
  • Correlation of loss events to applicable risk, policy, and control procedures, as well as correlation to insurance policies.

 

RSA Archer Loss Event Management provides:

  • Consolidated view of loss events by frequency amount, type, source, and owner
  • Clear understanding of the cause of loss events and the actions being taken to remediate problems that led to the loss event, including whether remediation plans are being executed on time, as planned
  • Greater engagement of business unit managers in the management of losses
  • Evidence of the design and effectiveness of an organization’s loss event program within a broader operational risk management program.

 

Today, organizations are faced with complex and fast moving operational risk challenges.  RSA Archer Loss Event Management is one element of an effective Integrated Risk Management program.  Stressing the agility and flexibility needed by today’s modern organizations, integrated risk management brings together the various domains of risk across business activities (horizontally), connecting the activities to the strategies and objectives of the organization on an aggregated basis (vertically). This approach to risk management provides leaders with the most holistic understanding of risk facing their organization so they can make truly informed decisions about where to deploy limited capital and human resources to produce optimized returns for the organization while maximizing the likelihood of achieving the organization’s objectives.

 

As your organization drives business growth, your risk management program must evolve and manage risk more holistically, with more agility and integration than before. Effectively managing loss events is one ingredient to demonstrating real progress and improvement in decreasing business risk.  RSA Archer can help your organization better understand and manage loss events on one configurable, integrated software platform. With RSA Archer solutions, organizations can efficiently implement risk management processes using industry standards and best practices and significantly improve their business risk management maturity.

 

For more information, visit RSA.com or read the Datasheet.

 

What is Operational Risk?

The Risk Management Association defines operational risk as “the risk of loss resulting from inadequate or failed internal processes, people, and systems, or from external events.” Examples of operational risk include natural and man-made disasters, cyber-attacks, errors, fraud, and regulatory or contractual non-compliance.

 

Why is Top-Down Risk Assessment so important?

Organizations today face a wide range of risks originating in different areas of their business, related to strategy, credit, corporate and regulatory compliance, interest rates, liquidity, market prices, operations (errors, fraud, and external events), and reputation, among others. While risks are spread out across an organization and often interrelate, it is difficult to get a holistic view of risk necessary to manage it efficiently and effectively.

 

The problem is further compounded with the introduction of new products and services, mergers and acquisitions, business process changes, and new and intensifying sources of fraud. In many organizations, risks are documented haphazardly in spreadsheets and documents without consistent use of a common approach, methodology, or rating scale. In addition, accountability for risk is tenuous because risks are not assigned to named managers and business units. This undermines accountability and increases the likelihood that a significant risk event will occur.

 

In addition, non-standardized risk management terminology, inconsistent risk assessment methodology and inconsistent risk rating scales mean there is no comprehensive visibility to or accountability in addressing known risks. With everyone speaking differently about risk, incomplete risk registers and inconsistent risk assessments can lead to bad risk management decisions, illogical resource allocation, potential violations of regulatory mandates and an overall poor risk management program.

 

Consistently documenting risks and controls and performing reliable risk assessments is essential to establishing an effective risk management program.

 

RSA Archer Top-Down Risk Assessment

RSA Archer Top-Down Risk Assessment enables practitioners to document risks and controls throughout the organization. Risks can be assessed on an inherent and residual basis, both qualitatively and across multiple risk categories using monetary values. Controls can be linked to the risks they treat for consideration as a part of a residual risk assessment. Risks and controls can be assigned to named individuals and organizational structure to establish appropriate accountability and to provide relevant reporting.

 

Key features include:

  • Catalog a consolidated view of risks and internal controls within the organization
  • Map risks to business processes, controls, higher-level risk statements and scenarios
  • Establish a library of agreed-upon scenarios and perform assessments on selected scenarios
  • Perform qualitative and monetary assessments of inherent and residual risk
  • Monitor risks against established tolerances and risk appetite
  • Enforce consistent terminology, risk assessment methodology and rating scales
  • Organized, managed process to escalate issues to ensure proper signoff/ approval of issues
  • Operationalize accountability for risks, controls, business processes, scenarios, risk assessments and outstanding issues
  • Establish delegated authorities for approving risk and enforce those authorities by automatically routing risk decisions to the authorized individuals
  • Visibility into risk and control inventory and assessment progress via predefined reports and risk dashboards

 

Today, organizations are faced with complex and fast moving risk challenges.  RSA Archer Top-Down Risk Assessment is one element of an effective Integrated Risk Management program.  Stressing the agility and flexibility needed by today’s modern organizations, integrated risk management brings together the various domains of risk across business activities (horizontally), connecting the activities to the strategies and objectives of the organization on an aggregated basis (vertically). This approach to risk management provides leaders with the most holistic understanding of risk facing their organization so they can make truly informed decisions about where to deploy limited capital and human resources to produce optimized returns for the organization while maximizing the likelihood of achieving the organization’s objectives.

 

As your organization drives business growth, your risk management program must evolve and manage risk more holistically, with more agility and integration than before. Effectively performing Top-Down risk assessments is one ingredient to demonstrating real progress and improvement in decreasing business risk.  RSA Archer can help your organization better understand and manage risk assessments on one configurable, integrated software platform. With RSA Archer solutions, organizations can efficiently implement risk management processes using industry standards and best practices and significantly improve their business risk management maturity.

 

For more information, visit RSA.com or read the Datasheet.

What is Third Party Governance?

RSA Archer Third Party Governance provides organizations the capability to monitor and manage the performance of the third parties with whom they do business.

 Why is the proper management of Third Party performance so important?

Organizations are increasingly using third parties to support their operations and to deliver products and services to their clients. Every organization entering into a third party relationship has expectations regarding how the third party’s product and services should perform.  It is particularly critical that third parties provide satisfactory performance wherever they are supporting customer-facing activities or contribute to the organization achieving its key objectives. Often performance expectations are formalized via contract by way of agreed-upon service level metrics unique to the product or service being delivered by the third party.   While contractually establishing service level metrics is a best practice, it is only the first step.  Organization’s need to monitor performance metrics throughout the life of each third party relationship and manage deteriorating third party relationships at the earliest possible time.  While an organization may have created some contractual recourse should a third party fail to perform, litigation and financial compensation do not solve the problems posed by underperforming third parties.  The best outcome is represented by third parties that live up to or exceed performance expectations.

 

RSA Archer Third Party Governance

RSA Archer Third Party Governance provides the capability to track the performance of individual third party engagements and to measure the performance of third parties across all of the engagements they are delivering to your organization. Third Party Governance provides the ability to document and track service level agreement metrics, and utilize a metrics library to promote consistency in assigning service level metrics to similar engagements.  Once performance metrics are established, actual performance data can be collected from named individuals or automatically via systems of record.  Stakeholders can be automatically notified if a third party’s performance begins to fall outside acceptable boundaries so that third party performance can be coached back to acceptable levels or remediation and contingency plans created and executed should the third party’s performance become irreparable.

 

Key features include:

  • Define and document performance metrics for third parties
  • Track all contractual service level agreement (SLA) metrics
  • Uncover deteriorating third party performance
  • Capture and monitor remediation plans until performance problems are resolved
  • Create performance metrics and associate them with individual product and service engagements
  • Capture performance metric data on an ongoing basis and score performance based on data collected
  • Report on performance of individual product and service engagements
  • Roll up engagement level performance to obtain overall third party performance profile

 

RSA Archer Third Party Governance enables organizations to:

  • Create and capture performance metrics and associate them with individual product and service engagements on an ongoing basis
  • Report on performance of individual product and service engagements and roll up engagement level performance to obtain an overall third party performance profile
  • Uncover deteriorating vendor performance and quickly resolve third party performance problems
  • More frequently exercise contract remedies due to poor performance
  • Avoid third party-related surprises and losses, and spend less time and money on third party performance remediation
  • Demonstrate the effectiveness of third party performance management programs to executive management and regulators

 

Today, organizations are faced with complex and fast moving challenges exacerbated by the very nature of rapidly expanding third party relationships.  RSA Archer Third Governance is one element of an effective Integrated Risk Management program.  Stressing the agility and flexibility needed by today’s modern organizations, integrated risk management brings together the various domains of risk across business activities (horizontally), connecting the activities to the strategies and objectives of the organization on an aggregated basis (vertically). This approach to risk management provides leaders with the most holistic understanding of risk facing their organization so they can make truly informed decisions about where to deploy limited capital and human resources to produce optimized returns for the organization while maximizing the likelihood of achieving the organization’s objectives.

 

As your organization drives business growth through an extended ecosystem strategy, your third party risk and performance management program must evolve and manage risk more holistically, with more agility and integration than before. Managing third party risk and performance is one ingredient to showing real progress and improvement and decreasing business risk.  RSA Archer can help your organization better understand and manage its third party relationships on one configurable, integrated software platform. With RSA Archer solutions, organizations can efficiently implement risk management processes using industry standards and best practices and significantly improve their business risk management maturity.

 

For more information, visit RSA.com or read the Datasheet.

 

What is Third Party Engagement?

A third party is any entity with which your organization has an actual or implied contractual relationship for the receipt of goods and services.  Besides being called a third party, these relationships may also be known as vendors or suppliers.  An Engagement refers to the actual product or service being received by way of a contract with a third party. 

 

RSA Archer Third Party Engagement provides organizations the capability to inventory all of the product and service engagements they are receiving from third parties.  Engagements can be mapped to the third parties supplying the product or service, and to the organization’s business units and business processes they support. Third party contacts can be documented and accountability for third party engagements can be established by named individual and by the business units that own the relationship. If you are utilizing the RSA Archer Third Party Engagement, Risk Management, and Governance use cases then the risk and performance of individual engagements can be established and risk and performance information can be rolled-up across all products and services delivered by a third party; and depicting it in aggregate at the appropriate third party organizational level.

 

Why is the proper management of Third Party Engagements so important?

Third parties may relate, to some degree, with every aspect of an organization.  They may impact your organization’s objectives and they support, in one way or another, the products and services your organization delivers.  They support business processes, introduce risk and affect and supplement the extended internal control environment of your organization.  They may provide assets and inputs to the organization such as hardware, software, physical space, and product inputs.  Acting as an agent of your extended organization, they are subject to your regulatory obligations and policies, and they may directly supplement your human resources through consultants and temporary labor, or extend your human resources by the nature of the services that they are providing.  You may have third parties that touch on every one of these elements of your business. 

There are numerous reasons organizations choose to engage third parties.  These include competing better; benefiting from a vendor’s expertise that you don’t have in-house; optimizing resources, acquiring resources (often more cheaply), transferring risk such as under insurance, and expanding market share by capitalizing on the third party’s presence in a market where you don’t currently have a presence, or by offering a more attractive product or service because of the third party’s expertise and capabilities.

Third parties are an extension of your business and, in the end, third parties introduce the same risk to your organization as if you internalized the activities.  In most cases, it is impossible to eliminate the risk altogether.  The best you can do is understand the risk and manage it within acceptable levels.

 

RSA Archer Third Party Engagement

RSA Archer offers the Third Party Engagement use case to consolidate the list of third party products and services your organization uses.

 

Key features include:

  • Catalog third parties, their business hierarchy, and the product and services engagements they deliver to your organization
  • Map third party products and services to the business processes they support
  • Roll up engagement risk assessments to obtain an overall third party risk profile
  • Catalog contracts and master services agreements associated with engagements
  • Execute contract risk assessments utilizing standardized questionnaires focused on minimum required contract language to mitigate and transfer risk
  • Capture the third party’s proof of insurance and evaluate the adequacy of the insurance relative to all of the engagements being delivered
  • Integrate the results of your business process impact analysis into your assessment of the inherent resiliency risk of each third party
  • Establish accountability for each third party engagement
  • Document and monitor remediation plans to bring risk within acceptable tolerance
  • Track exceptions related to third party engagements

 

With RSA Archer Third Party Engagement, you can:

  • Establish efficient management of your third party relationships
  • Know where, how, and why third parties are being used throughout your organization, and who is responsible
  • Identify inherently high risk third party products, services, and relationships
  • Better understand the adequacy of each third party’s proof of insurance,
  • Have fewer third party-related audit and regulatory findings
  • Establish the basis for an effective third party risk management program and allocation of scarce resources based on the most significant priorities
  • Provide transparency into third party relationships using robust notifications and reporting
  • Provide positive assurance to senior management, the Board, and regulators regarding the adequacy of the organization’s third party governance program

 

Today, organizations are faced with complex and fast moving challenges exacerbated by the very nature of rapidly expanding third party relationships.  The RSA Archer Third Party Engagement is one element of an effective Integrated Risk Management program.  Stressing the agility and flexibility needed by today’s modern organizations, integrated risk management brings together the various domains of risk across business activities (horizontally), connecting the activities to the strategies and objectives of the organization on an aggregated basis (vertically). This approach to risk management provides leadership with the most holistic understanding of risk facing the organization so they can make truly informed decisions about where to deploy limited capital and human resources to produce the most effective return to the organization.

 

As your company drives business growth through an extended business ecosystem strategy, your risk management program must evolve and manage risk with more agility and integration than before. Managing third party risk and performance is one ingredient to showing real progress and improvement and decreasing business risk.  RSA Archer can help your organization better understand and manage its third party relationships on one configurable, integrated software platform. With RSA Archer solutions, organizations can efficiently implement risk management processes using industry standards and best practices and significantly improve their business risk management maturity.

 

For more information, visit RSA.com or read the Datasheet.

What is Third Party Risk Management?

A third party is any entity with which your organization has an actual or implied contractual relationship for the receipt of goods and services.  Besides being called a third party, these relationships may also be known as vendors or suppliers.  An Engagement refers to the actual product or service being received by way of a contract with a third party. 

 

RSA Archer Third Party Risk Management provides organizations the capability to assess and manage the risks associated with their third party engagements.

 

Why is the proper management of Third Party Risk so important?

Organizations are increasingly using third parties to support their operations and deliver products and services to their clients. While it is possible to outsource many business activities to third parties, organizations retain the risks associated with their third party relationships. Many of these risks can be significant including regulatory compliance violations, customer and shareholder litigation, information security breaches, financial losses from errors, fraud and business interruption, reputation damage, and impediment to strategic objectives. Organizations need to understand the risks third party relationships pose to their organization and the adequacy of controls that their third party providers have in place to manage risk within acceptable boundaries.

 

RSA Archer Third Party Risk Management

RSA Archer Third Party Risk Management employs a series of risk assessment questionnaires to be completed by a third party to assess the third party’s internal control environment and collect relevant supporting documentation for further analysis. The results of these questionnaires are factored into a determination of the residual risk of each third party engagement across several risk categories (compliance/litigation, financial, information security, reputation, resiliency, strategic, sustainability, and fourth party risk).  Risk results are depicted for each engagement and are rolled up to the third party to depict their overall risk across all of the engagements they deliver to the organization. Risk assessment findings can be automatically captured and managed as exceptions and remediation plans can be established, assigned to accountable individuals, and monitored to resolution.

 

Key features include:

  • Consistent risk assessment and evaluation of third party controls
  • Capture and store supplemental documents such as SSAE-16s, financial statements, and PCI assessments, and monitor when refreshed documents are due
  • Capture declared critical fourth party relationships and understand the quality of governance your third party applies to their own third party relationships
  • Depiction of risk of overall third party relationship, across all engagements being delivered to your organization
  • Consolidated view into known issues
  • Organized, managed process to escalate issues
  • Visibility into known risks and efforts to close/address risks
  • Efficient program management and understanding of program status

 

RSA Archer Third Party Risk Management provides:

  • Methodical and standardized approach to risk assessment
  • Management and mitigation of identified issues and reduced time to resolution
  • Stronger, quicker response to emerging risks
  • Fewer third party related incidents and losses
  • Reduced program administration costs
  • Reduction of overall third party risk
  • Reduced repeat audit and regulatory findings
  • Better understanding of how third parties are used throughout the organization and the risks they pose

 

Today, organizations are faced with complex and fast moving challenges exacerbated by the very nature of rapidly expanding third party relationships.  RSA Archer Third Party Risk Management is one element of an effective Integrated Risk Management program.  Stressing the agility and flexibility needed by today’s modern organizations, integrated risk management brings together the various domains of risk across business activities (horizontally), connecting the activities to the strategies and objectives of the organization on an aggregated basis (vertically). This approach to risk management provides leadership with the most holistic understanding of risk facing the organization so they can make truly informed decisions about where to deploy limited capital and human resources to produce optimized returns for the organization.

 

As your company drives business growth through an extended business ecosystem strategy, your risk management program must evolve and manage risk more holistically, with more agility and integration than before. Managing third party risk and performance is one ingredient to showing real progress and improvement and decreasing business risk.  RSA Archer can help your organization better understand and manage its third party relationships on one configurable, integrated software platform. With RSA Archer solutions, organizations can efficiently implement risk management processes using industry standards and best practices and significantly improve their business risk management maturity.

 

For more information, visit RSA.com or read the Datasheet.

In their ongoing effort to clarify the concepts of integrated risk management (IRM) and digital risk management (DRM), Gartner has begun to discuss the interconnection of IRM and DRM with enterprise risk management (ERM).

 

 

Source: https://blogs.gartner.com/john-wheeler/irm-is-essential-for-digital-transformation-success/

 

I certainly agree with Gartner’s statement in their recent blog: “To keep pace with the increasing risk associated with digital transformation, organizations require an integrated approach to risk management. Not only is it essential to invest in integrated risk management (IRM) technology to enable this approach, it is also imperative to focus on the convergence of technology and operational risk. This convergence represents a key IRM use case called ‘digital risk management.’ Digital risk management (DRM) technology integrates the management of risks of digital business components — such as cloud, mobile, social and big data — and third-party technologies, such as artificial intelligence and machine learning, operational technology (OT), and the Internet of Things (IoT). DRM helps bridge the gap between the Chief Risk Officer (CRO), the Chief Information Officer (CIO) and the Chief Information Security Officer (CISO).”

 

ENTERPRISE RISK MANAGEMENT IS THE FOCUS

While Gartner introduced IRM and DRM concepts some time ago as part of operational risk management, what appears new in Gartner’s most recent IRM discussion is the explicit connection to ERM.  The ascendency of ERM as a business focus is not new.  In 2014, I reported on RIMS declaration that the practice of ERM had reached critical mass. This is borne out by our customers in the financial services industry, of whom 81% stated in a survey conducted last year that they were already using the RSA Archer Suite to support their ERM program!  That’s right, 81% of financial services customers surveyed are already integrating cyber risks with other kinds of operational risks, with their organization’s financial risks and risks to their strategies and objectives.  As RIMS stated in 2013 of ERM, “value is maximized when management sets strategy and objectives to strike an optimal balance between growth and return, goals and related risks, and efficiently and effectively deploys resources in pursuit of the entity’s objectives.”

 

THE FUTURE OF ERM?

I think it’s safe to assume, as with most things risk management-related, organizations vary in their approach to ERM.  We know that approaches to risk identification, risk assessment, risk evaluation and treatment, and monitoring all vary, as does the scope and granularity around the use of performance, risk, and control indicators.  And that’s fine. Everyone executes to their own unique risk management roadmap given the objectives of their management team, board of directors, and available human and capital resources.

Yet, the Committee of Sponsoring Organizations (COSO) of the Treadway Commission (remember this is the group that drove the Sarbanes-Oxley Act?) has laid out their goal and roadmap for ERM, as well.  In their 2016 update to the COSO ERM framework, they represented the complex interrelationship between risk profile, performance, and risk appetite in this one graphic:

 

                                          Source: Figure 4.2, COSO ERM Public Exposure Draft, June 2016

 

I’ll leave a discussion of the relationship of each of these variables and how an organization might go about generating this kind of understanding for themselves in one graphical representation for another time. For now, I think it is enough to consider some of the questions that must be answered to achieve the goal laid out by COSO ERM 2016:

  • How do I come up with a risk appetite statement that consistently encompasses all types of risk?
  • If risk capacity is that level of risk that would put my organization out of business, which risks are those and how do I assess them in a way to compare them to my risk capacity?
  • How do I aggregate all of my risks to generate a risk profile?
  • How do I measure target performance?
  • How do I correlate risk profile to performance, let alone visually depict the relationship?

 

Please add a comment.  I would love to hear from you and how you think these questions can be answered.

What is a Third Party Catalog?

The RSA Archer Third Party Catalog provides organizations the capability to inventory all of the third parties with whom they do business and to document their third parties in accordance with their organizational structure (parent company, subsidiary, sub-subsidiary). Third party contacts can be documented and accountability for third party relationships can be established by named individual and by the business units that own the relationship. If you are utilizing the RSA Archer Third Party Engagement, Risk Management, and Governance solutions then risk and performance information can be rolled-up across all products and services delivered by the third party and depicted in aggregate at the appropriate third party organizational level.

 

Why is the proper management of Third Parties so important?

A third party is any entity with which your organization has an actual or implied contractual relationship for the receipt of goods and services.  Besides being called a third party, these relationships are also known as vendor or supplier relationships. 

 

Third parties may relate, to some degree, with every aspect of an organization.  They may impact your organization’s objectives and they support, in one way or another, the products and services an organization delivers.  They support business processes, introduce risk and affect and supplement the extended internal control environment of your organization.  They may provide assets and inputs to the organization such as hardware, software, physical space, and product inputs.  Acting as an agent of the extended organization, they are subject to your regulatory obligations and policies, and they may directly supplement your human resources through consultants and temporary labor, or extend your human resources by the nature of the services that they are providing.  You may have third parties that touch on every one of these elements. 

 

There are numerous reasons organizations choose to engage third parties.  These include competing better; benefiting from a vendor’s expertise that you don’t have in-house; optimizing resources, acquiring resources (often more cheaply), transferring risk such as under insurance, and expanding market share by capitalizing on the third party’s presence in a market where you don’t currently have a presence or by offering a more attractive product or service because of the third party’s contributions.

 

Third parties are an extension of your business and, in the end, third parties introduce the same risk to your organization as if you internalized the activities.  In most cases, it is impossible to eliminate the risk altogether.  The best you can do is understand it and manage it down to an acceptable level.

 

RSA Archer Third Party Catalog

RSA Archer offers the Third Party Catalog use case as the starting point to consolidate your third party dependencies.

 

Key features include:

  • Catalog suppliers, partners, service providers and other third parties
  • Capture important details related to third parties, including contracts
  • Map internal business units to third parties
  • Manage contacts with third parties
  • Efficiently manage your third party relationships
  • Establish accountability for each third party relationship
  • Track exceptions related to third party relationships

 

With RSA Archer Third Party Catalog, you can:

  • Obtain an awareness of all third party relationships throughout the organization
  • Reduce time identifying third party relationships and contracts
  • Establish Accountability for individual supplier relationships and quickly identify relationship owners
  • Track contract terms, including notification of key contract events such as contract obligations, and renewal and expiration dates 

 

Today, organizations are faced with complex and fast moving challenges exacerbated by the very nature of rapidly expanding third party relationships.  The RSA Archer Third Party Catalog is one element of an effective Integrated Risk Management program.  Stressing the agility and flexibility needed by today’s modern organizations, integrated risk management brings together the various domains of risk across business activities (horizontally), connecting the activities to the strategies and objectives of the organization on an aggregated basis (vertically). This approach to risk management provides leadership with the most holistic understanding of risk facing the organization so they can make truly informed decisions about where to deploy limited capital and human resources to produce the most effective return to the organization.

 

As your company drives business growth through an extended business ecosystem strategy, your risk management program must evolve and manage risk with more agility and integration than before. Managing third party risk and performance is one ingredient to showing real progress and improvement and decreasing business risk.  RSA Archer can help your organization better understand and manage its third party relationships on one configurable, integrated software platform. With RSA Archer solutions, organizations can efficiently implement risk management processes using industry standards and best practices and significantly improve their business risk management maturity.

 

For more information, visit RSA.com or read the Datasheet.

 

Privacy Discussion Begins

I had the distinct pleasure Tuesday to sit in on a livestream of NIST Privacy Framework: Workshop #1.   Hosted by the National Institute of Science and Technology (NIST), Workshop #1 was the kick off of an initiative NIST is leading to develop a voluntary privacy framework.  Although the NIST Cyber Security Framework has been hugely popular across industries, NIST feels that it does not adequately address Privacy.  NIST’s objective is to establish “a voluntary Enterprise Risk Management tool that organizations can pick up and use to manage privacy risk.”  They have lofty goals that include producing a tool that can be used long into the future; encompasses emerging and unknown future technologies and uses of information; is as useful as NIST CSF; and to make the framework broad enough to be consistent with existing privacy and risk management standards, where practical! 

 

NIST recorded the three hour workshop and is going to make the recording available to anyone that wants to watch it.  I encourage you to do so as a lot of REALLY interesting concepts were discussed by some seriously qualified thought leaders in this space.  I’m super “geeked out” about this material and excited to share with you what I found most interesting.  None of this is final in any way but represents some of the conversations I found most compelling.

  • Privacy is defined by the harm, if any, inflicted upon an individual by the way their information is handled.
  • Harm is defined by each individual and may change over time.
  • One individual’s harm may be different than another individual’s harm and is almost certainly different from the harm to the business that was the source of the privacy-related harm to the individual.

I personally think it is brilliant to be defining privacy in terms of the harm that it presents to an individual.  However, it has significant risk management ramifications that will need to be worked out in the privacy framework.

 

Risk Management Ramifications of the NIST Privacy Framework 

Identification of Privacy Risk

Organizations will need to know everywhere they have information about individuals.  The use of scanning tools will increase in order to find information across the enterprise.  But the information you are looking for may not be the obvious: name, address, account number, account balance, health information, etc., The question may be: what information do we have about an individual that could be used in a way that could bring about harm to an individual? You also have to ask, if we give any individual’s information to a third party, what could the third party intentionally or unintentionally do with the information that could harm an individual?  Will third party assessments begin to include questions to find out what other information third parties might have that can be combined with the information you are sharing with them, that could cause harm to an individual?

 

Inherent Risk Assessments

Defining privacy in terms of harm to an individual will make inherent risk assessments more challenging and scenario-based.  You will most certainly need to think outside the box to consider all the different ways information you collect and handle could harm an individual. How will you determine whether your information collection, information handling and sharing with third parties, potential breaches and incident response will harm any individual and by how much?  Will you need to start asking individuals how they would feel if their information was breached or used in an unintended manner?  Will your organization need to periodically refresh its understanding of individual harm, particularly as new technologies and uses of information emerge?

 

You will need to stay abreast of every new and changed way information is collected, managed, shared with a third party, destroyed, etc. In each of these cases you will no doubt need to document what and why information is being collected, the information lifecycle from collection to destruction, the intended use of the information, and the numerous possible uses of the information that could cause harm to an individual, including through your extended third party ecosystem. 

If you do conclude that information you handle could cause harm to individuals, how will you rate the risk?  What is the measure of harm – anything from financial loss, embarrassment, harassment, loss of time from unwanted marketing, black mail, psycho-social manipulation, even physical harm and death? Many of these kinds of harms do not readily translate in financial terms.

 

Residual Risk Assessments

With cyber security risk you apply appropriate organizational and technical measures to reduce the likelihood and / or impact of unauthorized access, alteration, or destruction of the information.  Defining privacy risk as harm to an individual(s), you aren’t solely concerned with unauthorized access, alteration, and destruction.  Your intended and unintended use of the information could cause harm. At a minimum, organizational controls will take on a relatively greater importance to ensure you are effectively capturing and controlling residual risk.

 

Risk Evaluation

Let’s say that you do find a way to rate residual risk in terms of harm to individual(s).  Mature organizations that manage risk against risk appetites and tolerances will have to go back and look at those values and somehow incorporate harm to individuals.  How much harm and what type(s) of harm to individuals will organizations be comfortable with?

Summary

NIST is just beginning the process to come up with a Privacy Framework and nothing is set in stone yet.  The privacy conversation is just beginning but it benefits each of us and our organizations to try and shape the conversation so any privacy framework published by NIST provides meaningful value without undue complexity and implementation heart burn. 

2018 Gartner Integrated Risk Management

 

Gartner has named Dell / RSA Archer a Leader in its inaugural Integrated Risk Management Magic Quadrant published on July 16, 2018. This is just the latest in RSA Archer’s long history of a Leaders quadrant designation in Gartner Magic Quadrant reports, most recently including:

 

Shifting to Integrated Risk Management

In recent years, particularly among more mature GRC implementations, we believe Gartner had seen organizations were increasingly implementing multiple use cases to establish enterprise-wide risk management programs. In 2017, we observed that Gartner began reframing their assessment of the GRC market and risk and compliance management-related solutions in the context of Integrated Risk Management.

 

Gartner believes that “integrated risk management enables simplification, automation and integration of strategic, operational and IT risk management processes and data.” We feel Gartner’s depiction of integrated risk management brings together Digital Risk Management (DRM), Vendor Risk Management (VRM), Business Continuity Management (BCM), Audit Management (AM), Corporate Compliance Oversight (CCO), Enterprise Legal Management (ELM), IT Risk Management, and Strategic Risk Management, all around the hub of Operational Risk Management.

 Leaders Quadrant for RSA Archer

One of the greatest strengths of the RSA Archer Suite is enabling a customer to bring together and effectively integrate multiple use cases.  So to us it is no surprise that, among 16 vendors evaluated, Dell Technologies (RSA) was placed in the Leaders quadrant by Gartner. RSA is pleased to be positioned – yet again -- as a Leader in -- yet another – Gartner Magic Quadrant.  We believe this Integrated Risk Management MQ report shows a very positive evaluation of the RSA Archer Suite. 

 

 

Thank You to Our Customers!

We know that this Leader position could not have been achieved without the help and support of our customers, acting as critical references  in Gartner’s evaluation of the RSA Archer suite. Our sincerest thanks to all of you that have acted as a reference on our behalf!

 

The Future of GRC

The term ”governance, risk, and compliance” has been fading in relevance over the past several years as organizations have matured their risk management programs.  Many of our customers have already implemented integrated risk management or enterprise risk management programs.  RSA, too, has embraced integrated risk management as a representation of how organizations should mature their risk management programs. We have long acknowledged that information security professionals cannot be truly effective in their roles without embracing business risk management – and integrated risk management is a further evolution ofthis idea. In the end, GRC is not dying – rather, it is evolving into IRM, a more meaningful approach to bring the whole organization together to consistently and effectively identify, assess, evaluate, treat, and monitor risk.

 

Magic Quadrant for Integrated Risk Management; Published: 16 July 2018; Analyst(s): John Wheeler, Jie Zhang, Earl Perkins

This graphic was published by Gartner, Inc. as part of a larger research document and should be evaluated in the context of the entire document. The Gartner document is available upon request from 2018 Gartner Magic Quadrant for Integrated Risk Management Solutions

 

Gartner does not endorse any vendor, product or service depicted in its research publications, and does not advise technology users to select only those vendors with the highest ratings or other designation. Gartner research publications consist of the opinions of Gartner's research organization and should not be construed as statements of fact. Gartner disclaims all warranties, expressed or implied, with respect to this research, including any warranties of merchantability or fitness for a particular purpose.

Remember the hullabaloo around GDPR?  Well, it went into effect a little over a month ago and already there is litigation pending with Supervisory Authorities in 4 EU countries!  The first complaints filed pertaining privacy concerns affected by the EU regulation is aimed at several major companies, all of which are U.S. based.

 

The First GDPR Complaints

Complaints have been filed against several U.S. based companies.  The suits range in size from one litigant to class actions, representing 9,000 to 10,000 EU data subjects.  As these stories unfold,  no one knows how the lawsuits will progress or whether any of these companies will be fined by an EU Supervisory Authority.   However, GDPR continues to be an initiative affecting many companies. 

 

What we do know from these early lawsuits are three things:

 

  • U.S. companies are not going to be immune to GDPR litigation
  • Even if no fines are levied, each of these companies must devote expensive legal resources to defending against these suits.
  • If you are a U.S. based company handling information about EU data subjects, you need to make sure you are ready for GDPR, including being able to demonstrate your compliance should an EU Supervisory Authority make an inquiry.

 

GDPR Preparation Basics

Every company has to consider the impact of the GDPR on its own business requirements and operations.  There are some basics that stand out as good fundamentals for GDPR efforts and privacy programs, in general.

 

Security Risk Assessment: Article 32 of the GDPR outlines appropriate elements of a security risk assessment process to ensure controls and risk are appropriately designed and implemented. An effective risk assessment process accelerates the identification of the linkage between risks and internal controls, reducing GDPR compliance gaps and improving risk mitigation strategies.

Breach Response: Article 33 of the GDPR outlines specific requirements for notification of a personal data breach to the supervisory authority. Obviously, the goal of any security team is to prevent these kinds of breaches, but breaches can still occur.  Accomplishing this objective will require a combination of processes and technical capabilities including security incident management, security operations and breach management, as well as tools for deep monitoring and analysis of system related security data, such as system events, coupled with strong forensics capabilities.

Data Governance: The GDPR highlights that data governance is a crucial element of effective data management practices.  Organizations must protect personal data in a number of different ways, and must be able to demonstrate due diligence in keeping accurate records of processing activities.  A basic element of data governance is controlling who has access to personal data within the organization.  These requirements are in keeping with Identity and Access Management (IAM) and Data Governance best practices.

Compliance Program Management:  At the end of the day, GDPR is a regulatory issue.  A compliance program should provide the framework for establishing a scalable and flexible environment to document, manage and test your organization’s policies and procedures to comply with the GDPR.

Organizations with these basics in place can have a stronger foundation to address emerging issues, creating a more proactive and resilient environment while reducing the cost of GDPR compliance.

For more information, check out RSA's resources on GDPR - specifically this paper on GDPR Compliance.  For RSA Archer Community members, we have several Practitioner Tours highlighting the RSA Archer privacy use cases - Data Governance and Privacy Program Management.

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