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RIMS Report: The California Consumer Privacy Act of 2018

With legislation introduced in California this year to protect consumers’ personal data, a new RIMS professional report, Understanding the California Consumer Privacy Act of 2018 (CCPA) highlights the importance for risk professionals and their organizations to prepare and adjust business operations to remain compliant under the law.

Authored by RIMS External Affairs Committee member Teri Cotton Santos, the report addresses the rights provided to consumers under the CCPA, the obligations it creates for businesses, as well as practical steps companies should take to prepare for its implementation date.

The CCPA was signed into law in June and became the broadest U.

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S. framework imposing consent and disclosure obligations on businesses that collect personal information on California consumers. Similar to the European Union’s General Data Protection Regulation (GDPR), the law applies to companies collecting personal information on California consumers whether or not the company is based in the state. The clock is ticking for companies to update their operations and processes, as the CCPA becomes effective on Jan. 1, 2020.

“How organizations use and collect personal information continues to be a top concern for regulators and many consumers,” Santos said. “Now is the time for risk professionals to have discussions with internal stakeholders about the implementation of the CCPA and its impact on their organization’s operations and strategy.

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The report is currently available exclusively to RIMS members. To download the report, visit RIMS Risk Knowledge library at www.RIMS.org/RiskKnowledge. For more information about the Society and to learn about other RIMS publications, educational opportunities, conferences and resources, visit www.RIMS.org.

How the Internet of Things Benefits Risk Management

IoT cities
An increasingly digital world is resulting in companies across all industries reassessing how they approach risk management. Thanks to the connectedness of devices brought about by the Internet of Things (IoT), executives have much more information at their disposal for assessing risk than before.

IoT is a network of devices that collect and exchange data—think back to the classic example of your fridge ordering fresh milk before it runs out. This is quickly becoming a fact for businesses that rely more and more on being connected to remote devices for competitive advantage.

For risk managers, IoT boils down to introducing a layer of technology on top of the business. Operations do not have to be reinvented. This provides organizations that are reliant on managing risks with an indispensable tool.

Increased, relevant real-time data

In the insurance industry, this promises much more than just monitoring the location of a vehicle, the temperature of its load, and the performance of a driver. By equipping a company with more sensors and devices linked to the internet, organizations are able to gather significantly more real-time data to drive business value. This also has a big impact on managing risks.

For example, when a contractor’s portable toilets get dropped off, there is often no physical address to use. This creates complications when another driver or team has to locate the units a few days later for cleaning and maintenance. Using internet-linked sensors, however, the provider can easily find the toilets and quickly improve operational efficiencies. Another example is using IoT to assist in tagging assets with Radio Frequency Identification (RFID) tags. This assists with monitoring everything from the service intervals on equipment like cranes to ensuring that generators have the correct fuel levels.

The growth of IoT is also seeing a massive uptake in interest from startups to look at exploiting demand with innovative solutions.

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Wearable devices for e-health monitoring, for example, presents an opportunity for consumers to take more control towards preventative care and gives healthcare professionals richer, real-time insight on patient behavior during treatments.

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IoT gives decision-makers the ability to spot trends, adapt to changing market conditions and improve their strategies. What’s more, an IoT-led approach can be applied to any business—whether a retailer, medical practice, startup, or even a construction company.

Managing IoT risks

Despite the advantages, companies need to be mindful of how to protect against IoT risks, such as gaining access to information being fed from devices back to the head office. Security, as with any new piece of technology, has to be an integral part of utilizing IoT in the company.

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Scanning for vulnerabilities now extends beyond the network and devices such as smartphones, tablets, and laptops. IT departments need to ensure the security of machine-to-machine units, RFID tags, and so on. Fortunately, none of this is insurmountable. Taking due diligence and evaluating the cyber security strategy on an on-going basis should be a matter of course in a digital world. Again, IoT is providing the impetus to do so.

Relying on IoT as an enabling technology means risk managers are committing to the digital age. The payoff is that technology can give organizations greater flexibility in their approaches to efficiency, cost reduction and risk mitigation than in previous years.

Why Aren’t We Performing Risk Management Well?

Whenever a project is being planned, risk management has to be part of the equation – things rarely go smoothly or completely as expected, and there will always be areas that present more risks than others. Whether they affect the projected timeframes, budgets or outcomes, it is the job of the project manager to identify them and ensure that provisions are in place to limit their impact should they occur.

However, failures are made in risk management every day – they helped to trigger the economic crisis in 2008, demonstrating that even the world’s biggest banks, which take financial and logistical risks every day, are not immune to risk mismanagement. With this in mind, it’s understandable that smaller projects and processes might suffer from errors made in risk management.

Why aren’t we performing risk management well, then? With project management an ever-growing sector and more and more jobs being created every day, the next generation of risk managers needs to be able to identify issues in order to rectify them.

Unknown Unknowns

One of the most problematic aspects of risk management is the concept of “unknown unknowns” – the risks that we can’t predict and don’t even know could occur. As thorough as a risk management plan might be, there are some areas that it just can’t cover because they technically do not exist until the project has started and will arise as a result of the ongoing work.

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There is little that can be done about unknown unknowns – the only way that they can be completely avoided is if the project is never started, which is not a viable option.

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Any project inherently contains risks, but they can be risks that work out positively for the project and the organization. There is every chance that unknown unknowns may turn out that way.

Lack of Data

A lot of project risks are identified using historical data, which isn’t always credible – in the stock market, it is impossible to figure out future trends by using past events, and it’s the same here. However, data can be utilized to an extent, which means that the job is made a lot more difficult when it isn’t available.

A recent survey by the Economist Intelligence Unit states that more than half of risk executives at banks around the world have insufficient data to support a robust risk management strategy – therefore, there is no reason to suggest that, should the situation be the same in other industries, they would be any better equipped to produce a decent risk management strategy with the same data deficiencies.

Intimidation

On a very basic level, it can be quite intimidating to think about the number of risks that a project might possess, and risk managers can be concerned about seeming overly negative, affecting people’s opinions of the project and potentially the methods and processes used to complete the project. One might argue that if someone lacks this kind of forthrightness, they should not be involved in project management, but it is a weakness that has to be legislated for.

To not perform risk management thoroughly, however, smacks of incompetence and costs the organization as a whole both time and money. The responsible thing is to highlight risks so that they can be planned for in the event that they occur.

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Don’t worry about telling stakeholders anything they don’t want to hear – it just might trigger a different, better way of doing things.