A team member breaches data privacy unintentionally. How can you ensure accessibility for the team?

Imagine you’re part of a high-performance sports team. If a play goes awry during a crucial game, the coach immediately reviews the footage to understand what happened and why. The goal is to learn from the mistake, adjust tactics, and prevent it from happening again. Similarly, when a data breach occurs, you need to swiftly assess what went wrong and who was affected. Then, gather your team to discuss the incident openly. Just like refining game strategies, this review helps everyone understand the importance of data privacy and ensures you’re better prepared for the future.

La evaluaciòn del impacto es crucial para conocer el alcance que tendrìa en paralelo revisariamos varios puntos medulares que nos permitan conocer en donde se encuentra el eslabòn màs dèbil en esta cadena de gobierno de datos. Tambìen serìa importante generar evaluaciones constantes estos punto medulares de acceso a la informaciòn para prevenir este tipo de eventos

High level: Assess Impact: Identify compromised data, understand the breach’s cause, and determine the affected individuals or systems Contain the Breach: Take immediate actions to stop unauthorized access, recover records, and secure breached systems. Assign a responsible team to lead the investigation Communication: Inform internal stakeholders (DPO, privacy officers, risk managers, etc) and, if necessary, external entities (Privacy Commissioner, affected individuals). Prevent Future Breaches: Review and update data privacy policies, conduct regular training, and enhance security measures like encryption and access controls. So much more to say. This is only the tip of an expensive iceberg.

Em minha experiência , e somando com as ações já citadas , recomendo estabelecer políticas claras de acesso e uso de dados: Definindo com clareza quais dados podem ser acessados, por quem e para quais finalidades. Garantir que todos os membros da equipe estejam cientes dessas políticas com os devidos registros.

Balancing data privacy with team accessibility is challenging but achievable with the right approach. First, invest in regular training so everyone understands data privacy laws and best practices. Make sure access is tightly controlled, giving team members only the data they need. Protect sensitive information with masking and encryption, and have clear, accessible policies that everyone follows. Monitoring tools and regular audits are crucial to quickly detect and address potential breaches. Foster a culture of accountability where people feel responsible for data privacy and can report issues without fear. Finally, leverage technology solutions that automate access control and provide real-time alerts for suspicious activities.

After an unintentional data breach we experienced, we learned firsthand how critical it is to revisit and refine our data governance policies. I remember the moment when we discovered the breach—it was a wake-up call. We took a deep dive into the incident, pinpointed where our policies fell short, and made necessary updates. This included tightening access controls and boosting team training. The goal was to make our policies both robust and practical, ensuring our team could work effectively while protecting sensitive data. It taught us that ongoing adaptation and clear guidelines are vital for a secure, collaborative environment.

Revising data governance policies following data breach is important in preventing future incidents. Policy Weakness Identification: Based on the incident analysis identify weaknesses in your current data governance policies. Regular Audits: Conduct regular audits to ensure compliance with the updated data governance policies. Employee Training: Enhance the training provided to team members ensuring they understand the updated protocols & importance of data security. Flexibility in Protocols: Popularly, role-based access control(RBAC) can be used to ensure employees only have access to the data they need for their job roles. Incident Analysis: Identify how breach occurred, what data was compromised & any vulnerabilities that were exploited.

When writing policies and procedures operate a ‘privacy centric’ approach. This means that you will want to consider risk on an individual basis rather than in the collective sense. Name and Work detail (e.g. job title, company and address) The name and work details of someone who works in retail may be considered a lesser risk that someone working in a nuclear power plant. It is important to recognise that an individual’s data may be more sensitive by association, due to who their employer is or their job role/ function. Not all personal data is equal in terms of risk. This should be reflected in policies such as your risk management policy.

Review what are the existing policies and understand the root cause behind the data breach. During performing the review if it is observed that there are some areas which need to be better, the policy should be revised to accommodate the enhancements.

This could be a part of CAPA following deviation investigation. Documented evidence is important to draw out any solution. Policy may be already outlines all necessary secure steps and it is lack of training or execution of policy.

A cada treinamento realizado após incidentes e violações documentadas e mitigadas, a especificidade aumenta. É possível ir sentindo o que cada colaborador possui déficits ou dificuldades em matéria de segurança e governança, e, assim, ir lapidando o conhecimento que é passado a eles.

Training people and machines it's an art. People need practical examples and practice them. Data breach training is no different. How to act on this case after the storm? Indicate the problem to different groups within the company that have different jobs, as each group will solve it in a different way. Different conflict resolutions result in a more accurate process.

In today's dynamic organizations, monitoring access to sensitive data is crucial. The purpose limitation principle should be adopted to limit access to specific, stated purposes. Automated tools should be used to implement this principle, rather than manual processes, to ensure authorized access and minimize data breach risks. Automated tools provide transparent and auditable records of access requests, approvals, and revocations, demonstrating compliance with data protection regulations.

There is no 100% complete protection. An aligned team knows what to do when a problem occurs. Priority order: 1- Training 2- Application 3- Inspection If the training is applied to real cases and analyzed jointly, application and supervision become the consequence of a procedure.

RBAC with the least privilege principle + automated monitoring and alerts can be used to eliminate the majority of data privacy breaches.

More specifically, it is recommended to review accesses and privileges, there has to be balance between controlling/ monitoring, and enough freedom to create and develop. Whenever security, governance and privacy is seen as an impediment people will resist and avoid it, finding clever ways to burn security layers. That is why is important to fully understand the roles within the company and also share the responsibility of being privacy and security driven.

Every incident should be documented with proper root cause analysis and need to be reviewed with team to avoid these cases repeating in the future.

Unintentional data breaches often stem from a lack of awareness or negligence, sometimes due to over confidence. To address this, it is crucial to conduct regural brainstorming sessions and trainings among the team members. Gaming and virtual setup solutions also helps in improving the security posture. These activities help analyse the impact and determine the incidence response requirements for various scenarios. Note that the response strategies will be different depending on the types of systems and processess involved, hence to be specific for your environment.

Create a breach mitigation mindset. Similar to a risk mindset, every individual should have the empowerment to consider a breach scenario in their data interactions. Any unauthorised use of data ( whether by internal employees or external hackers) is a breach and should be treated with the same importance. In the event of a breach, first and foremost action is to isolate and contain the impact. Post which restore to BAU state . Next move in to root cause analysis and permanent fixes. Then comes the stage of further strengthening controls to prevent re-occurrence. Finally continuously monitor and enhance controls

The road to hell is paved with good intentions 😊 actually, security controls & Policy is one of key aspect to consider when assess the impact & apply corrective action, use data masking/ Encryption techniques to hide sensitive information would be an effective control to solve such common cases

Before anything else, Contain the Breach - Identify and isolate affected systems to prevent further data loss. Notify affected parties w.r.t. legal requirements of notifications.

It is important to remember that a breach is not just where personal data is compromised (e.g. stolen by hackers). A breach is where the confidentiality, integrity or access is comprimised. Confidentiality: where there is an unauthorised or accidental disclosure of or access to personal data Integrity: where there is unauthorised or accidental alteration of the data Availability: where there is an accidental or loss of access to or destruction of personal data.