What GDPR Means in Practice for Irish Business

The General Data Protection Regulation (GDPR) is a European directive aimed at ring-fencing consumer data against illegal or unnecessary access. There is nothing to discuss or debate with local politicians, or the Irish Data Protection Commissioner for that matter. As a European directive, it has over-riding power. To obtain an English version, please visit this link, and select ?EN? from the table of languages.

As you reach for your tea, coffee or Guinness after sighting it, you will be glad to know the Irish Data Protection Commissioner has the lead in turning this into business English we understand. The following diagram should assist you to obtain a quick overview of the process we all have to go through. In this article, we briefly describe what is inside Boxes 1 to 12. The regulation comes into force on 25 May 2018 so we have less than a year to get ready.

The 12 Essential Steps to Implementing the General Data Protection Act

1. Create awareness among your people of what is coming their way. The GDPR has given our regulator discretion to dish out fines up to ?20,000,000 (or 4% of total annual global turnover, whichever is greater) so there is determination to make this happen.

2. Become accountable by understanding the consumer data you hold. Why are you retaining it, how did you obtain it, and why did you originally collect it. Now you know it is there, how much longer will you still need it? How secure is it in your hands, have you ever shared it?

3. Open a communication channel with your staff, your customers, and anyone else using the data. Share how you feel about how accountable you have been with the information in the past. Explain how you plan to comply with the GDPR in future, and what needs to change.

4. Understand the personal privacy entitlement of the subjects of the information. They have rights to access it, correct mistakes, remove information, restrict its use, decline direct marketing, and copy it to their own files. What needs to change in your systems to assure these rights?

5. Issue a policy for allowing consumers access to their information you hold. You must process requests within a month, and you may not charge for the service unless your cost is excessive. You may decline unfounded or excessive demands within your policy guidelines.

6. Adapt to the requirement that you must have a legal basis for everything you do with, and to consumer data. You need to be in a position to justify your actions to the Irish Data Protection Commissioner in the event of a complaint. Having a legitimate interest is no longer sufficient.

7. Ensure that consumer consent to collect, use, and distribute their data is ?freely given, specific, informed, and unambiguous.? From 25 May 2018 onward, this consent will be your only ground to do so. You cannot force consent. Your benchmark becomes what the GDPR says.

8. Issue rules for managing data of underage subjects. This is currently under review and we are awaiting results. Put systems in place to verify age. Set triggers for where guardians must give consent. Make sure age is verifiable. Use language young people understand.

9. Introduce a culture of openness and honesty, whereby breaches of the GDPR are detected, reported, investigated, and resolved. You will have a duty to file a GDPR report with the Data Protection Commissioner within 72 hours, thus it is important to fast track the process.

10. Introduce a policy of conducting a privacy assessment before taking new initiatives. The GDPR calls for ?privacy by deign?, and we need to engineer it in. This may be the right time to appoint a data controller in your company, and start implementing the GDPR while you have time.

11. You may also need to appoint a data protection officer depending on the size of your business. Alternatively, you need to add managing data protection compliance to an employee?s duties, or appoint an external data-protection compliance consultant.

12. Finally, and you will be glad to know this is the end of the list, the GDPR has an international flavour in that multinational organisations will report into the EU Lead Supervisory Authority. This will manage the process centrally while consulting national data authorities.

The GDPR is a project we all need to complete. If we are out of line, it is in our interests to get things straightened out. Once everything is in place, the task should not be too onerous. Getting there could be the pain.

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The Connection Between Six Sigma and CRM

Six Sigma is an industrial business strategy directed at improving the quality of process outputs by eliminating errors and system variables. The end objective is to achieve a state where 99.99966% of events are likely to be defect free. This would yield a statistical rating of Sigma 6 hence the name.

The process itself is thankfully more user-friendly. It presents a model for evaluating and improving customer relationships based on data provided by an automated customer relations management (CRM) system. However in the nature of human interaction we doubt the 99.99966% is practically achievable.

Six Sigma Fundamentals

The basic tenets of the business doctrine and the features that set off are generally accepted to be the following:

  1. Continuous improvement is essential for success
  1. Business processes can be measured and improved
  1. Top down commitment is fundamental to sustained improvement
  1. Claims of progress must be quantifiable and yield financial benefits
  1. Management must lead with enthusiasm and passion
  1. Verifiable data is a non-negotiable (no guessing)

Steps Towards the Goal

The five basic steps in Six Sigma are define the system, measure key aspects, analyse the relevant data, improve the method, and control the process to sustain improvements. There are a number of variations to this DMAIC model, however it serves the purpose of this article. To create a bridge across to customer relationships management let us assume our CRM data has thrown out a report that average service times in our fast food chicken outlets are as follows.

<2 Minutes 3 to 8 Minutes 9 to 10 Minutes >10 Minutes
45% 30% 20% 5%
Table: Servicing Tickets in Chippy?s Chicken Caf?s

Using DMAIC to unravel the reasons behind this might proceed as follows

  • Define the system in order to understand the process. How are customers prioritised up front, and does the back of store follow suit?
  • Break the system up into manageable process chunks. How long should each take on average? Where are bottlenecks most likely to occur?
  • Analyse the ticket servicing data by store, by time of day, by time of week and by season. Does the type of food ordered have a bearing?
  • Examine all these variables carefully. Should there for example be separate queues for fast and slower orders, are there some recipes needing rejigging
  • Set a goal of 90% of tickets serviced within 8 minutes. Monitor progress carefully. Relate this to individual store profitability. Provide recognition.

Conclusion

A symbiotic relation between CRM and a process improvement system can provide a powerful vehicle for evidencing customer care and providing feedback through measurable results. Denizon has contributed to many strategically important systems.?

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Solutions to Password Overload

If only technologists had their way, passwords and PINs would have long been replaced with more innovative (and admittedly, better) security solutions. But such is not the case. Those alternative solutions, which include biometrics, smart cards, and password fobs, effective as they may be, are just way too expensive to implement.

So although passwords and PINs may not be here to stay, they certainly won’t be going away soon either.

Why keeping passwords in memory is no longer possible

A couple of decades ago, it would have been nearly impossible to crack an eight-character password using brute force. Today, however, advancements in computing power are rendering the typical passwords of the past easily decipherable, forcing us to come up with passwords that are not only much longer, but also much more complex and hence difficult to recall.

For instance, memorable words like your favourite character (e.g. ‘skywalker’) may have been acceptable then, but not anymore. Today?s security systems will encourage you to insert numbers or even other keyboard characters as a means to once again counter brute force. Hence, ‘sk5%ywa936lker@#’ may be more acceptable.

Remembering that one alone can be pretty daunting.

To further complicate matters, the number of applications that require passwords for access is much greater than before even for a single end user. Ordinary end users have to keep track of passwords for their email account, network login, workstation login, online services, and so on.

The burden is even greater for your IT admins, who have to remember a larger collection of passwords that protect business critical systems and applications. Clearly, the team in charge of your IT security will need a way to manage all these passwords.

Password management solutions

Existing password management solutions typically come in the form of software applications that store passwords. Basically, all you need to remember are your login details for the app a.k.a. the ?master password?. Once you’ve gained access inside, you can then retrieve any password you stored there.

Some of these apps are installed in portable devices like Pocket PCs, PDAs, or smartphones, which you would normally take along with you. For as long as the device stays with you, your passwords will be in safe hands. What’s more, you can retrieve them anywhere you go.

But obviously, there’s a problem. What if the device gets misplaced or stolen? Although the person who ends up with your device may not be able to gain access into the app and your passwords, neither will you. A better solution would therefore be an app that can be accessed anywhere but is not susceptible to getting lost.

Web-based password manager

A web-based password manager fits the bill. You don’t have to take it with you, but still you can access it almost anywhere. A typical web-based password manager will have all your passwords stored in a centralised, highly secure location.

If you want, you can even use your mobile password manager along with the web-based one. Ideally, your web-based password manager would have a copy of all the end-user passwords as well as the master passwords of your organisation.

With an easy to access but highly-secure web-based password manager, you no longer have to come up with passwords that (ironically) are supposed to be easy to remember but hard to crack at the the same time.

Furthermore, password managers are ideal for keeping passwords that have to be changed every-now-and-then; a requirement that’s becoming all too common in organisations bent on enforcing more stringent controls.

Can you do away with the Project Initiation Meeting?

Project initiation meetings are often skipped to fast-track projects. Once a sponsor is found, organisations go straight to project planning and execution. But based on our own experience, holding a project initiation meeting can actually eliminate many issues that may crop up in the future and hence may speed things up instead in the long run.

It is in the project initiation meeting where your project objectives and scope are clarified and all stakeholders are brought to the same page. Project sponsors and stakeholders will have to know in a nutshell what is needed from them, what the possible risks are, what different resources are required, and so on. So that, when it’s time to proceed to the next phase, everyone is already in-sync.

So what are taken up in such a meeting? Perhaps an actual example can help. Sometime in the past, we set out to work on an eCommerce website project. After conducting the project initiation meeting, these were some of the things we were able to accomplish:

  • Identified deliverables e.g. site design, interface to payment system, etc.
  • Come up with the project phases
  • Agreed what should be in and out of scope
  • Defined the acceptance test criteria
  • Identified possible risks
  • Identified the possible training and documentation work needed
  • Established whether any analysis was required, e.g. as with regards to payment interfaces
  • Formulated disaster recovery plans
  • Defined roles and responsibilities
  • Drafted timelines and due dates

Aren’t these covered in project planning? If the project is a big one, the answer is no. In a large project, project planning is a much more exhaustive activity. In a project initiation meeting, only the basic framework is defined.

Some questions may still remain unanswered after a project initiation meeting, but at least you already know what answers you need to look for. In the example we gave earlier, we left the meeting knowing that we needed:

  • a list of all necessary hardware to estimate the costs
  • to identify possible dependencies we might have with third parties
  • to identify what software had to be bought and what skills we needed to hire

When it was time to proceed to project planning, everyone involved already knew what direction we were taking. In effect, by not skipping the project initiation meeting, we were able to avoid many potential obstacles.

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