8 Steps to Manage Vendor Data Privacy Compliance
Around the world, new regulations on the collection and usage of personal data are changing workflows for major organizations. Following the passage of legislation like General Data Protection Regulation (GDPR) in the EU and the California Consumer Privacy Act (CCPA), businesses are auditing privacy practices and creating much stricter guidelines when they select partners and vendors.
With tighter regulations about the way consumer data is collected and used, organizations have to increase scrutiny for every party that has access to personal data. The entire system is only as secure as the weakest part, so it’s more important than ever to vet external parties and maintain visibility into their data practices.
Here are eight important steps organizations can take to ensure that vendors aren’t jeopardizing data privacy compliance.
Step 1: Audit your existing data privacy system
Before you do anything else, examine what’s currently in place to understand the changes that need to be made to maintain compliance with new regulations. You want to avoid reinventing the wheel and make adjustments without slowing down the business or adding risks. After that self-examination, conduct the same check on your network of vendors. It’s imperative that you have a 360-degree understanding of vendors’ business practices and overall reliability before entering or continuing business relationships.
Step 2: Build internal consensus across stakeholders
Before taking significant action, it’s important to line up with other internal teams and agree on a framework for success. There should be a standard process for vetting vendors about their data management practices, complete with a set of standard criteria that can be applied to every organization. There also needs to be a protocol for sorting vendors into tiers based on potential risks and how to conduct additional review if necessary. These tiers should address the severity of compliance risk, the business impact of that vendor and any other criteria that is deemed important.
Step 3: Develop digital processes for due diligence and risk assessment
A common best practice is to vet vendors for data privacy compliance with a standardized questionnaire. That document will require the vendors to provide information about how they use data, what kind of data they work with and the security of storage/access. Ultimately, this information can be used to determine whether they will expose your business to risk. A good way to streamline that process is with a digital questionnaire, rather than relying on a long PDF form. Using DocuSign Guided Forms by SmartIQ, any organization can create a digital risk assessment document with a simplified, step-by-step experience to guide vendors through a complex process. New questions can even adapt based on previous responses, giving any organization the ability to adjust the line of questioning as needed. This results in a faster, more personalized experience for vendors with minimal friction.
Step 4: Increase visibility into contracts before signing
Most procurement contracts don’t contain standardized language about data privacy issues. That means even if your organization has a searchable repository of existing agreements, it’s still hard to automatically find the relevant part of a contract that covers data privacy issues. Instead, manual review is the only way to ensure that you find all the language pertaining to that subject. To help with that search, DocuSign Intelligent Insights offer prebuilt Procurement and Data Privacy Insight Accelerators that can leverage AI to scan vendor contracts and surface relevant language. This technology is useful to analyze existing contracts as well as those currently under negotiation. Intelligent Insights can scan the copy of an agreement and instantly provide a conceptual understanding of commitments around personal data use.
Step 5: Update contracts automatically
In the back-and-forth process of agreement negotiation, contracts need to be repapered. DocuSign CLM offers a simple, straightforward way to streamline that work. By hosting the document in a centralized repository, your company can allow multiple stakeholders to collaborate on a document, redlining, negotiating and leveraging a library of preapproved terms. This is an easy way to automate some of the most manual parts of the repapering process, which makes the entire process easier, faster, cheaper and less error-prone.
Step 6: Implement technology with business context
To comply with relevant data privacy regulations, you need to make some important system changes and ensure that data flows correctly. Once you’ve figured out which changes are necessary, it’s time to select technology that can fill any gaps. When you’re implementing new solutions, pay attention to your specific business needs and relations with existing vendors to decide what works best for your organization and team members.
Step 7: Communicate with stakeholders and train staff
To effectively uphold your data privacy responsibilities, you need to be transparent about internal processes and maintain a clear audit trail for retroactive review. Data privacy efforts are a two-way street, you should be clear with your vendors about your technology and processes. You need to communicate with relevant stakeholders on new processes and train your staff thoroughly to make sure everyone follows the standard protocol.
Step 8: Run the program
Once you’ve done the work to map out a compliant data privacy program for your vendors, the final step is to execute. After the first seven steps, everyone on your team should have a clear understanding of what the organization needs to do to remain in compliance and how that impacts their personal workflows. In addition to improving internal systems and raising data privacy standards for vendors, you need to build a system to track program metrics. You also need to establish a method of collecting feedback from stakeholders and vendors about areas for improvement or adjustment. It will also make future regulation-driven changes easier to implement.
To learn more about how your company can navigate vendor relationships and remain in compliance with new data privacy regulations, download the Managing the Challenges with Burgeoning Data Privacy Laws whitepaper by SIG (Sourcing Industry Group).