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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How SOA can help Transformation

Undoubtedly, today’s business leaders face myriad challenges ranging from fierce market competition to increasing market unpredictability. In addition, the modern consumer is more informed and in control of what, where and how they purchase. Couple these challenges with effects of globalization, and you will appreciate that need for business transformation is more of a necessity than a privilege.

As recent business trends show, top companies are characterized by organizational and operational agility. Instead of being shaken by rapid technological changes and aftershocks associated with market changes, they are actually invigorated by these trends. In order to survive in these turbulent times, business leaders are opting to implement corporate transformation initiatives to develop leaner, more agile and productive operations. In line with this, service oriented architecture (SOA) has emerged as an essential IT transformation approach for implementing sustainable business agility.

By definition, service oriented architecture is a set of principles and techniques for developing and designing software in form of business functionalities. SOA allows users to compile together large parts of functionality to create ad hoc service software entirely from the template software. This is why it is preferred by CIOs that are looking to develop business agility. It breaks down business operations into functional components (referred to as services) that can be easily and economically merged and reused in applicable scenarios to meet evolving business needs. This enhances overall efficiency, and improves organizational interconnectivity.

SOA identifies shortcomings of traditional IT transformation approaches that were framed in monolithic and vertical silos all dependent on isolated business units. The current business environment requires that individual business units should be capable of supporting multiple types of users, multiple communication channels and multiple lines of business. In addition, it has to be flexible enough to adapt to changing market needs. In case one is running a global business enterprise, SOA-enabled business transformation can assist in achieving sustainable agility and productivity through a globally integrated IT platform. SOA realizes its IT and business benefits by adopting a design and analyzing methodology when developing services. In this sense a service consists of an independent business unit of functionality that is only available through a defined interface. Services can either be in the form of nano-enterprises or mega-enterprises.

Furthermore, with SOA an organization can adopt a holistic approach to solve a problem. This is because the business has more control over its functions. SOA frees the organization from constraints attributed to having a rigid single use application that is intricately meshed into a fragmented information technology infrastructure. Companies that have adopted service oriented architecture as their IT transformation approach, can easily repurpose, reorganize and rescale services on demand in order to develop new business processes that are adaptable to changes in the business environment. In addition, it enables companies to upgrade and enhance their existing systems without incurring huge costs associated with ‘rip and replace’ IT projects.

In summary, SOA can be termed as the cornerstone of modern IT transformation initiatives. If properly implemented great benefits and a sharp competitive advantage can be achieved. SOA assists in transforming existing disparate and unconnected processes and applications into reusable services; creating an avenue where services can be rapidly reassembled and developed to support market changes.

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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.

Measure it to manage it with smart meters

Measure it to manage it. This saying applies perfectly to energy management. Effectively managing energy use is virtually impossible with unreliable measurement devices in place or worse still, no measurements at all. Smart meters are a smart way to measure energy and water usage giving you more control over the amount of energy or water usage.

Smart energy meters:
Smart meters are indeed a smart way to get insight into your energy use which brings more security and a better environment. They can also enable you to get Smart Energy Reports that are a personalised guide to energy efficiency.

Other benefits of smart meters:

? You are able to generate simple graphs and charts showing you where you use your energy and money

? Consumption of gas and electricity is broken down. This implies that one can be able to view their spending at a glance

? Smart meters track consumption on a monthly basis enabling you to compare your own consumption against other similar households

? By tracking energy consumption and spending over time, one can be able to view the history and assess the impact of their energy efficiency measures over a particular period

Smart water meters:
Smart meters are not only used for measuring energy use, they are also used to measure water usage efficiency. Water efficiency is essential for management of sustainable water resources.

Water resources have been diminishing over time posing a challenge for water users and water suppliers to seriously look for ways to manage water efficiency. The need for accurate, adequate and reliable measurement and monitoring practices of water consumption in organisations can therefore not be overlooked.

Timely collection and analysis of water use data, and relaying this data in a timely manner to the water user, can result in significant changes in water use behaviour. Other benefits include instant detection of areas where water wastage is occurring e.g. leakages hence action is taken to save water. Similar to energy data, water data collected by smart metering systems is also vital in designing water efficiency and recycling systems as well as the improvement of demand management policies and programs.

The use of smart meters to monitor water consumption enables users to analyse, and interpret the data collected. This feedback enables users to change their behaviours.

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