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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Spreadsheet Fraud

To any company executive or business owner, the mere possibility of fraud can be enough to send alarm bells ringing – for good reason. In a prolonged recession, the last thing investors would want to discover is a huge, gaping hole where supposedly a neat profit should have been. Also to find out that such loss was brought about by deliberately falsified accounting and poor spreadsheet controls only makes the situation even more regrettable.

Why?

Because these losses would not have occurred had there been a stronger risk management program in place and more stringent quality control on critical data to begin with.

But given the nature of a spreadsheet system i.e. its sheer flexibility and easy accessibility, plus the fact that they were never intended to be enterprise-level tools, there are no hard and fast rules for auditing spreadsheets. Also because of the lack of internal controls for end user computing (EUC) applications, in this case spreadsheets, you can’t expect these systems to yield consistently accurate results.

In fact, most managers assume that major spreadsheet errors should result in figures that are blatantly out of touch with how things stand in the real world, making these errors easily detectable.

Well they assumed wrong. You’ll find cases where the losses ran to millions of dollars without anyone being the wiser.

In instances of fraud, the problem becomes more complicated as these errors are deliberately hidden and cleverly disguised, perhaps one erroneous cell at a time. Even if these cover-ups started out with smaller figures that may have had negligible impact on a company?s operation, the cumulative costs of these ?insignificant? errors multiply exponentially as the spreadsheets are reused and utilised as bases for other related reports.

While there is no generally accepted definition of the term ?spreadsheet fraud?, its quite easy to identify one when a case crops up. Fraud arising from spreadsheets are typically characterised by:

Fallacious inputs – correct figures are deliberately replaced with false values.

Erroneous outputs owing to data alteration – hyperlinks are linking to the wrong spreadsheets or cells; use of macros or special lines of code which are understandable only to the person who developed the code.

Concealment of critical information – can be done with easy ?tweaks? such as hidden rows and columns, using the same colour for both the font and the background, or hard coding additional values into a cell.

There is nothing really highly-sophisticated or technical in any of these methodologies. But without internal spreadsheet controls in place, it would take a discerning eye and a thorough review to catch the inconsistencies contained in a spreadsheet fraught with errors. Also, if these errors are knowingly placed there, the chances of finding them are close to nil.

Learn more about our server application solutions and discover a better way to protect your company from spreadsheet fraud.

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Spreadsheet Risks in Banks


Top 10 Disadvantages of Spreadsheets


Disadvantages of Spreadsheets – obstacles to compliance in the Healthcare Industry


How Internal Auditors can win the War against Spreadsheet Fraud


Spreadsheet Reporting – No Room in your company in an age of Business Intelligence


Still looking for a Way to Consolidate Excel Spreadsheets?


Disadvantages of Spreadsheets


Spreadsheet woes – ill equipped for an Agile Business Environment


Spreadsheet Fraud


Spreadsheet Woes – Limited features for easy adoption of a control framework


Spreadsheet woes – Burden in SOX Compliance and other Regulations


Spreadsheet Risk Issues


Server Application Solutions – Don’t let Spreadsheets hold your Business back


Why Spreadsheets can send the pillars of Solvency II crashing down

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ESOS Guide for UK Manufacturers Available

The Engineering Employers’ Federation (EEF) is the UK’s largest sectoral structure. Its goal is to promote the interests of manufacturing, engineering and technology-based businesses in order to enhance their competitiveness.

EEF has positioned itself in London and Brussels in order to be in a position to lobby at EU and Westminster level. Part of its role is helping its members adapt to change and capitalise on it. When it discovered that a third of UK manufacturers must comply with ESOS (and 49% had not even heard of it) EEF decided it was time to publish a handbook for its members.

According to EEF’s head of climate and environment policy Gareth Stace, For the many manufacturers that have already taken significant steps to improve energy efficiency, ESOS can be viewed as a ?stock taking exercise?, ensuring that momentum is maintained and new measures are highlighted and taken when possible?.

He goes on to add that others that have not begun the process should view it as an ‘impetus’ to go head down and find the most cost-effective ways to slash energy costs. Ecovaro adds that they would also have the opportunity to reduce carbon emissions almost as a by-product.

Firms with more than 250 employees, over 250 million revenue or both must comply with ESOS across all UK sectors. In simplest terms, they must have conducted an energy audit by 5th December 2015, and logged their energy saving plan with the Environmental Agency that is Britain?s sustainability watchdog.

The Department of Energy & Climate Change (DEEC) that oversees it believes that large UK businesses are wasting ?2.8 billion a year on electricity they do not need. Clearly it makes sense to focus on larger targets; however EcoVaro believes those halfway to the threshold should voluntarily comply if cutting their energy bills by 25% sounds appealing.

We are able to assist with interpreting their energy audits. These are often a matter of installing sub-meters at distribution points, and reading these for a few representative months to establish a trend. Meters are inexpensive compared to electricity costs, and maintenance teams can install them during maintenance shutdowns.

Ecovaro helps these firms process the data into manageable summaries using cloud-based technology. This is on a pay-when-used basis, and hence considerably cheaper than acquiring the software, or appointing a consultant.

Without Desktop Virtualisation, you can’t attain True Business Continuity

Even if you’ve invested on virtualisation, off-site backup, redundancy, data replication, and other related technologies, I?m willing to bet your BC/DR program still lacks an important ingredient. I bet you’ve forgotten about your end users and their desktops.

Picture this. A major disaster strikes your city and brings your entire main site down. No problem. You’ve got all your data backed up on another site. You just need to connect to it and voila! you’ll be back up and running in no time.

Really?

Do you have PCs ready for your employees to use? Do those machines already have the necessary applications for working on your data? If you still have to install them, then that’s going to take a lot of precious time. When your users get a hold of those machines, will they be facing exactly the same interface that they’ve been used to?

If not, more time will be wasted as they try to familiarise themselves. By the time you’re able to declare ?business as usual?, you’ll have lost customer confidence (or even customers themselves), missed business opportunities, and dropped potential earnings.

That’s not going to happen with desktop virtualisation.

The beauty of?virtualisation

Virtualisation in general is a vital component in modern Business Continuity/Disaster Recovery strategies. For instance, by creating multiple copies of virtualised disks and implementing disk redundancy, your operations can continue even if a disk breaks down. Better yet, if you put copies on separate physical servers, then you can likewise continue even if a physical server breaks down.

You can take an even greater step by placing copies of those disks on an entirely separate geographical location so that if a disaster brings your entire main site down, you can still gain access to your data from the other site.

Because you’re essentially just dealing with files and not physical hardware, virtualisation makes the implementation of redundancy less costly, less tedious, greener, and more effective.

But virtualisation, when used for BC/DR, is mostly focused on the server side. As we’ve pointed out earlier in the article, server side BC/DR efforts are not enough. A significant share of business operations are also dependent on the client side.

Desktop virtualisation (DV) is very similar to server virtualisation. It comes with nearly the same kind of benefits too. That means, a virtualised desktop can be copied just like ordinary files. If you have a copy of a desktop, then you can easily use that if the active copy is destroyed.

In fact, if the PC on which the desktop is running becomes incapacitated, you can simply move to another machine, stream or install a copy of the virtualised desktop there, and get back into the action right away. If all your PCs are incapacitated after a disaster, rapid provisioning of your desktops will keep customers and stakeholders from waiting.

In addition to that, DV will enable your user interface to look like the one you had on your previous PC. This particular feature is actually very important to end users. You see, users normally have their own way of organising things on their desktops. The moment you put them in front of a desktop not their own, even if it has the same OS and the same set of applications, they?ll feel disoriented and won’t be able to perform optimally.

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