enterprise modeling Archives

In light of recent, high-profile data breaches, it’s past-time we re-examined strategic data governance and its role in managing regulatory requirements.

News broke earlier this week of British Airways being fined 183 million pounds – or $228 million – by the U.K. for alleged violations of the European Union’s General Data Protection Regulation (GDPR). While not the first, it is the largest penalty levied since the GDPR went into effect in May 2018.

Given this, Oppenheimer & Co. cautions:

“European regulators could accelerate the crackdown on GDPR violators, which in turn could accelerate demand for GDPR readiness. Although the CCPA [California Consumer Privacy Act, the U.S. equivalent of GDPR] will not become effective until 2020, we believe that new developments in GDPR enforcement may influence the regulatory framework of the still fluid CCPA.”

With all the advance notice and significant chatter for GDPR/CCPA, why aren’t organizations more prepared to deal with data regulations?

In a word? Complexity.

The complexity of regulatory requirements in and of themselves is aggravated by the complexity of the business and data landscapes within most enterprises.

So it’s important to understand how to use strategic data governance to manage the complexity of regulatory compliance and other business objectives …

Designing and Operationalizing Regulatory Compliance Strategy

It’s not easy to design and deploy compliance in an environment that’s not well understood and difficult in which to maneuver. First you need to analyze and design your compliance strategy and tactics, and then you need to operationalize them.

Modern, strategic data governance, which involves both IT and the business, enables organizations to plan and document how they will discover and understand their data within context, track its physical existence and lineage, and maximize its security, quality and value. It also helps enterprises put these strategic capabilities into action by:

Understanding their business, technology and data architectures and their inter-relationships, aligning them with their goals and defining the people, processes and technologies required to achieve compliance.
Creating and automating a curated enterprise data catalog, complete with physical assets, data models, data movement, data quality and on-demand lineage.
Activating their metadata to drive agile data preparation and governance through integrated data glossaries and dictionaries that associate policies to enable stakeholder data literacy.

Five Steps to GDPR/CCPA Compliance

With the right technology, GDPR/CCPA compliance can be automated and accelerated in these five steps:

Catalog systems

Harvest, enrich/transform and catalog data from a wide array of sources to enable any stakeholder to see the interrelationships of data assets across the organization.

Govern PII “at rest”

Classify, flag and socialize the use and governance of personally identifiable information regardless of where it is stored.

Govern PII “in motion”

Scan, catalog and map personally identifiable information to understand how it moves inside and outside the organization and how it changes along the way.

Manage policies and rules

Govern business terminology in addition to data policies and rules, depicting relationships to physical data catalogs and the applications that use them with lineage and impact analysis views.

Strengthen data security

Identify regulatory risks and guide the fortification of network and encryption security standards and policies by understanding where all personally identifiable information is stored, processed and used.

How erwin Can Help

erwin is the only software provider with a complete, metadata-driven approach to data governance through our integrated enterprise modeling and data intelligence suites. We help customers overcome their data governance challenges, with risk management and regulatory compliance being primary concerns.

However, the erwin EDGE also delivers an “enterprise data governance experience” in terms of agile innovation and business transformation – from creating new products and services to keeping customers happy to generating more revenue.

Whatever your organization’s key drivers are, a strategic data governance approach – through business process, enterprise architecture and data modeling combined with data cataloging and data literacy – is key to success in our modern, digital world.

If you’d like to get a handle on handling your data, you can sign up for a free, one-on-one demo of erwin Data Intelligence.

For more information on GDPR/CCPA, we’ve also published a white paper on the Regulatory Rationale for Integrating Data Management and Data Governance.

California Consumer Privacy Act (CCPA) compliance shares many of the same requirements in the European Unions’ General Data Protection Regulation (GDPR).

While the CCPA has been signed into law, organizations have until Jan. 1, 2020, to enact its mandates. Luckily, many organizations have already laid the regulatory groundwork for it because of their efforts to comply with GDPR.

However, there are some key differences that we’ll explore in the Q&A below.

Data governance, thankfully, provides a framework for compliance with either or both – in addition to other regulatory mandates your organization may be subject to.

CCPA Compliance Requirements vs. GDPR FAQ

Does CCPA apply to not-for-profit organizations?

No, CCPA compliance only applies to for-profit organizations. GDPR compliance is required for any organization, public or private (including not-for-profit).

What for-profit businesses does CCPA apply to?

The mandate for CCPA compliance only applies if a for-profit organization:

Has an annual gross revenue exceeding $25 million
Collects, sells or shares the personal data of 50,000 or more consumers, households or devices
Earns 50% of more of its annual revenue by selling consumers’ personal information

Does the CCPA apply outside of California?

As the name suggests, the legislation is designed to protect the personal data of consumers who reside in the state of California.

But like GDPR, CCPA compliance has impacts outside the area of origin. This means businesses located outside of California, but selling to (or collecting the data of) California residents must also comply.

Does the CCPA exclude anything that GDPR doesn’t?

GDPR encompasses all categories of “personal data,” with no distinctions.

CCPA does make distinctions, particularly when other regulations may overlap. These include:

Medical information covered by the Confidentiality of Medical Information Act (CMIA) and the Health Insurance Portability and Accountability Act (HIPAA)
Personal information covered by the Gramm-Leach-Bliley Act (GLBA)
Personal information covered by the Driver’s Privacy Protection Act (DPPA)
Clinical trial data
Information sold to or by consumer reporting agencies
Publicly available personal information (federal, state and local government records)

What about access requests?

Under the GDPR, organizations must make any personal data collected from an EU citizen available upon request.

CCPA compliance only requires data collected within the last 12 months to be shared upon request.

Does the CCPA include the right to opt out?

CCPA, like GDPR, empowers gives consumers/citizens the right to opt out in regard to the processing of their personal data.

However, CCPA compliance only requires an organization to observe an opt-out request when it comes to the sale of personal data. GDPR does not make any distinctions between “selling” personal data and any other kind of data processing.

To meet CCPA compliance opt-out standards, organizations must provide a “Do Not Sell My Personal Information” link on their home pages.

Does the CCPA require individuals to willingly opt in?

No. Whereas the GDPR requires informed consent before an organization sells an individual’s information, organizations under the scope of the CCPA can still assume consent. The only exception involves the personal information of children (under 16). Children over 13 can consent themselves, but if the consumer is a child under 13, a parent or guardian must authorize the sale of said child’s personal data.

What about fines for CCPA non-compliance?

In theory, fines for CCPA non-compliance are potentially more far reaching than those of GDPR because there is no ceiling for CCPA penalties. Under GDPR, penalties have a ceiling of 4% of global annual revenue or €20 million, whichever is greater. GDPR recently resulted in a record fine for Google.

Organizations outside of CCPA compliance can only be fined up to $7,500 per violation, but there is no upper ceiling.

Data Governance for Regulatory Compliance

While CCPA has a more narrow geography and focus than GDPR, compliance is still a serious effort for organizations under its scope. And as data-driven business continues to expand, so too will the pressure on lawmakers to regulate how organizations process data. Remember the Facebook hearings and now inquiries into Google and Twitter, for example?

Regulatory compliance remains a key driver for data governance. After all, to understand how to meet data regulations, an organization must first understand its data.

An effective data governance initiative should enable just that, by giving an organization the tools to:

Discover data: Identify and interrogate metadata from various data management silos
Harvest data: Automate the collection of metadata from various data management silos and consolidate it into a single source
Structure data: Connect physical metadata to specific business terms and definitions and reusable design standards
Analyze data: Understand how data relates to the business and what attributes it has
Map data flows: Identify where to integrate data and track how it moves and transforms
Govern data: Develop a governance model to manage standards and policies and set best practices
Socialize data: Enable all stakeholders to see data in one place in their own context

A Regulatory EDGE

The erwin EDGE software platform creates an “enterprise data governance experience” to transform how all stakeholders discover, understand, govern and socialize data assets. It includes enterprise modeling, data cataloging and data literacy capabilities, giving organizations visibility and control over their disparate architectures and all the supporting data.

Both IT and business stakeholders have role-based, self-service access to the information they need to collaborate in making strategic decisions. And because many of the associated processes can be automated, you reduce errors and increase the speed and quality of your data pipeline. This data intelligence unlocks knowledge and value.

The erwin EDGE provides the most agile, efficient and cost-effective means of launching and sustaining a strategic and comprehensive data governance initiative, whether you wish to deploy on premise or in the cloud. But you don’t have to implement every component of the erwin EDGE all at once to see strategic value.

Because of the platform’s federated design, you can address your organization’s most urgent needs, such as regulatory compliance, first. Then you can proactively address other organization objectives, such as operational efficiency, revenue growth, increasing customer satisfaction and improving overall decision-making.

You can learn more about leveraging data governance to navigate the changing tide of data regulations here.