This is part two of a two-part blog series about facing uncertainty and creating ability and resilience in data management
Being resilient in the face of uncertainty
No matter the source of the political uncertainties that can impact international data flows, organizations need to be prepared. The outcome of good preparation should be the agility that enables organizational resilience in the face of politically-motivated disruption to international data flows. Three key steps organizations should take include:
1) Understand the organization’s data flows – Organizations need to know all the ways in which its data is transferred across borders. This includes which borders are being crossed, and in which direction. They also need to know which of these data flows contain personal data, and what technology is being used to transmit the data.
2) Determine safeguards – Data is transferred between organizations, and so the organization needs to know who is receiving the data on the other end. Next, the organization needs to review the standard contractual clauses with these organizations around data sharing, and be sure that they contain language that will stand up in the event of political change. If data sharing is within the organization itself, then the binding corporate rules about information sharing across borders need to be examined. Having the right language in place to guide cross-border data sharing is the best safeguard an organization can put in place.
3) Implement safeguards – Once organizations know the status of their cross-border data sharing language both internally and with external entities, the organization then needs to put in place the right safeguards. Updating contractual language, or putting in place new corporate policies, are significant remediation projects that will need to be carefully planned and executed. Once these programs are completed, internal documentation, such as process registers, will need to be updated.
Organizations need to take proactive steps to manage political uncertainty around cross-border data flows by increasing resilience. Putting a program in place to ensure business-necessary data continues to flow will allow an organization to thrive competitively at a time when other organizations have failed to take such steps. Ensuring international data flows through good data governance is important today and will continue to be important in the future.
