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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Six Sigma

Six Sigma has received much attention worldwide as a management strategy that is said to have brought about huge improvements and financial gains for such big-name companies as Allied Signal, General Electric (GE) and Motorola.

If you want to give your business the chance to attain the same resounding success, Six Sigma could be the method that will steer you towards that direction.

What is Six Sigma?

So what really is it? Six Sigma is a business management tool that was developed using the most effective quality improvement techniques from the last six decades. Basing its approach on discipline, verifiable data, and statistical calculations, Six Sigma aims to identify the causes of defects and eliminate them, thereby resulting in near-perfect products that meet or exceed customer’s satisfaction.

The core concept behind the Six Sigma method is that if an organisation can quantify the number of “defects” there are in a particular process, improvement activities can be implemented to eliminate them, and get as close to a “zero defects” scenario as possible. Defect here is defined as any process output that fails to meet customer specifications.

Six Sigma is also unique from other programs in that it calls for the creation of a special infrastructure of people within the organisation (“Champions“, “Black Belts“, “Green Belts“) who are to be expert in the methods.

Six Sigma Methodologies

When implementing Six Sigma projects, two methodologies are often employed. Although each method uses five phases each, these two are distinguished from each other using 5-letter acronyms and their specific uses.

DMAIC ? is the project methodology used to improve processes and maximise productivity of current business practices. The 5 letters stand for:

  • D ? Define (the problem)
  • M ? Measure (the main factors of the existing process)
  • A ??Analyse?(the information gathered to deter mine the causes of defects)
  • I ? Improve (the current process based on the analysis)
  • C ? Control (all succeeding processes so as to minimise additional defects)

DMADV – is the method most suitable if your business is looking to create new products or designs. The acronym stands for:

  • D ? Define (product goals as the consumer market demands)
  • M ? Measure (and identify product capabilities and risks)
  • A ??Analyse?(to create the best possible design)
  • D ? Design (the product or process details)
  • V ? Verify (the design)

How does Six Sigma differ from other quality programs?

If you think that Six Sigma is just another one of those business strategies that produce more hype than actual results, think again. Six Sigma uses three key concepts that sets it apart from other business management methods.

  • It is strictly a data-driven approach, where assumptions and guesswork do not figure in the decision making.
  • It focuses on achieving quantifiable financial results ? the bottom line ($) ? as much as giving emphasis on customer satisfaction.
  • It requires strong management leadership, while at the same time creating a role for every individual in the organisation.

Is Six Sigma right for your business?

While many other organisations such as Sony, Nokia, American Express, Xerox, Boeing, Kodak, Sun Micro-systems and many other blue chip companies have followed suit in adopting Six Sigma, the truth is, any company — whether you have a large manufacturing corporation, or a small business specialising in customer service.

Certainly, there is a lot more to Six Sigma than what you can probably absorb in one sitting or reading.

With our wide range of business management consultancy services, we can help you understand the Six Sigma method in the context of your business. We can also help you establish your improvement goals, set up your program, and train your own team of “champions” who can lead in implementing your Six Sigma goals.

Find out more about our Quality Assurance services in the following pages:

Month End Accounting the way it should Be Today

Month end accounting has always been a business critical exercise. Without the balance sheet, income statement, and other financial reports this exercise ultimately produces, management could not make informed decisions to keep the company in the right direction and at the ideal operational speed.

Now, in order to maintain optimal business velocity, month end activities have to be carried out as swiftly and as accurately as possible. Delays will only inhibit managers from reacting and effecting necessary adjustments in time. Inaccurate information, on the other hand, obviously lead to bad decisions.

But that’s not all. Never has the month end close been as demanding as it is today. Regulations like the Sarbanes-Oxley Act, Solvency II, Dodd-Frank Act, and others, which call for more stringent controls and more robust risk management practices, are now forcing companies to find better ways to face the end of the month.

Sticking to old month-end practices while striving to achieve regulation compliance can either cost a company more (if they add manpower) or simply bog it down (if they don’t). Among the worst of these practices is the use of spreadsheets.

These User Developed Applications (UDAs) are very susceptible to errors. (See spreadsheet risks)

What’s more, consolidating data from spreadsheets as well as carrying out reconciliations on them is very time consuming. These activities usually require data from outside sources – i.e. a workstation in a different department, building, or (in the case of really large corporations) geographical locations.

Furthermore, if one of these sources fail, the financial reports won’t be complete. This is not a far-fetched scenario, considering that spreadsheet storage and backup is typically carried out by the average end user. This leaves the spreadsheet data vulnerable to hard disk crashes, virus attacks, and unexpected disasters.

Thus, in order to produce accurate financial reports on time all the time, you need a financial/IT solution that offers optimal provisions for risk management, collaboration, backup, and business continuity. Learn about server-based solutions and discover a better way to carry out month end accounting.

The General Data Protection Regulation & The Duty to use Encryption

The General Data Protection Regulation, abbreviated to GDPR, raised a storm when it arrived. In reality, it merely tightened up on existing good practice according to digital security specialists Gemalto. The right to withhold consent and to be forgotten has always been there, for example. However, the GDPR brings a free enforcement service for consumers, thus avoiding the need for third party, paid assistance.

The GDPR Bottom Lines for Data Security
Moreover, the GDPR has penalties it can apply, of the order that might have a judge choking on his wig. Under it, data security measures such as pseudonymisation (substitution of identifying fields) and encryption (encoding including password protection) have become mandatory. Businesses must further respect their client data by:

a) Storing it in a secure environment supported by robust services and systems

b) Having proven measures to restore availability and access after a breach

c) Being able to prove frequent effectiveness testing of these measures.

The General Data Protection Regulation places an onus on businesses to report any data breaches. This places us in a difficult situation. We must either face at least a wrist slap upon reporting failures. Alternatively, pay a fine of up to ?10 million, or 2% of total worldwide annual turnover.

The Engineered Weak Link in the System
Our greatest threat of breach is probably when the data leaves our secure environment, and travels across cyberspace to an employee, stakeholder, collaborator, or the client themselves. Since email became open to attack, businesses and individuals have turned to sharing platforms like Dropbox, Google Drive, Skydrive, and so on. While these do allow an additional layer of password protection, none of these has proved foolproof. The GDPR may still fine us heavily, whether or not we are to blame for the actual breach.

How Hacking is Approaching Being a Science
We may make a mistake we may regret, if we do not take hacking seriously. The 10 worst data hacks Identity Force lists are proof positive that spending lots of money does not guarantee security (any more than having the biggest stock of nuclear weapons). We have to be smart, and start thinking the way that hackers do.

Hacker heaven is finding an Experian or a Dun & Bradstreet that may have shielded 143 million, and 33 million consumer records respectively, behind a single, flimsy cyber-security door. Ignorance is no excuse for them. They should simply have known better. They should have rendered consumer data unreadable at individual record level. The hackers could have found this too demanding to unpick, and have looked elsewhere.

How Data Encryption Can Help Prevent Hackers Succeeding
Encrypting data is dashboard driven, and businesses need not concern themselves about it works. There are, however, a few basic decisions they must take:

a) Purge the database of all information held without explicit permission

b) Challenge the need for the remaining data and purge the nice-to-haves

c) Adopt a policy of encrypting access at business and customer interfaces

d) Register with three freemium encryption services that seem acceptable

e) After experimenting, sign up for a premium service and be prepared to pay

Factors to Consider When Reaching a Decision
Life Hacker?suggests the following criteria although the list is a one-size-fits-all

a) Is the system fast, simple, and easy to operate

b) Can you encrypt hidden volumes within volumes

c) Can you mass-encrypt a batch of files easily

d) Do all other files remain encrypted when you open one

e) Do files automatically re-encrypt when you close them

f) How confident are you with the vendor, on a scale of 1 to 10

It may be wise to encrypt all the files on your system, and not just your customer data. We are always open to a hack by the competition after our strategic planning. If we leave the decision up to IT, then IT, being human may take the easy way out, and encrypt as little as possible.

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