Having to remain compliant with regulations such as GDPR and SWIFT CSP can sometimes be as complicated as a maze. With the right guidance, businesses can find innovative ways to address these challenges while seizing new opportunities to drive growth and build trust. Industry experts, such as Jan Vanhaecht, teach businesses to better adapt to and fulfill new industry standards. More importantly, they serve to create a stronger and more resilient Congressional operation.

Understanding the Compliance Landscape

The world of data privacy and security is intimidating, threatening even, with tons of acronyms and granular requirements. GDPR, or General Data Protection Regulation, provides safeguards for people’s personal information in the EU. At the same time, the SWIFT Customer Security Programme works to protect the SWIFT network to ensure the safe global passage of international financial transactions. Jan Vanhaecht is an expert in taking these tricky regulations and turning them into pragmatic plans of action that businesses can deploy. He knows why compliance failing is not just checking the boxes, but about fostering a culture with security and trust at its foundation.

Vanhaecht's approach involves a deep understanding of a business's operations, identifying potential vulnerabilities, and developing tailored solutions. You need to adopt technical protections as table stakes to help mitigate risk. Define unambiguous policies and procedures, invest in employee training, and foster a culture of security awareness and vigilance. His work is a cool reminder that compliance isn’t a one-time magic bullet, but a healthy, living process to improve.

Key Steps to Achieve and Maintain Compliance

So, what can enterprises do in real terms to sense and yet surpass regulator expectations as seen within GDPR and more recently SWIFT CSP? Here's a step-by-step guide, informed by Vanhaecht's expertise:

  1. Conduct a thorough data audit: Knowing what data you hold, where it is stored, and how it is used is the first step in protecting personal information. This involves mapping data flows and identifying potential risks.
  2. Create a Record of Processing Activities (ROPA): This is a crucial step in GDPR compliance, as it helps businesses understand their data processing activities and ensure transparency. The ROPA should document the purpose of processing, categories of data subjects, and recipients of data.
  3. Implement data minimization and accuracy: Businesses should only collect and process the minimum amount of personal data necessary to achieve their purposes, and ensure that the data is accurate and up-to-date. Regularly review and update data to maintain accuracy.
  4. Establish clear data protection policies and procedures: Businesses should have clear policies and procedures in place for data protection, including data subject rights, data breaches, and data transfers. These policies should be easily accessible to employees and regularly reviewed.
  5. Appoint a Data Protection Officer (DPO): A DPO can help businesses ensure GDPR compliance and provide guidance on data protection issues. The DPO acts as a point of contact for data subjects and supervisory authorities.

Addressing SWIFT CSP Challenges

SWIFT CSP compliance has its own challenges. Here are some common pitfalls and how to overcome them:

  • Insufficient resources: Companies may not have the necessary resources, including personnel, budget, and technology, to implement and maintain the required security controls. To solve this, prioritize critical controls and consider outsourcing certain functions to specialized providers.
  • Lack of understanding of controls: Companies may not fully understand the 32 SWIFT security controls, which can lead to incomplete or incorrect implementation. Engage with SWIFT CSP experts to gain a clear understanding of the requirements and best practices.
  • Inadequate risk assessment: Companies may not conduct thorough risk assessments to identify vulnerabilities and prioritize mitigation efforts. Use a structured risk assessment methodology to identify and assess potential threats.
  • Inadequate incident management plan: Companies may not have a comprehensive incident management plan in place to respond to security incidents. Develop a detailed incident response plan that outlines roles, responsibilities, and procedures for handling security incidents.
  • Third-party vendor risks: Companies may not properly assess and mitigate risks associated with third-party vendors. Conduct thorough due diligence on third-party vendors and implement appropriate security controls.

The Importance of Auditors and Trust

Achieving compliance involves a crucial three-sided relationship: the business entity, its advisors, and the auditors. Businesses often rely on advisors to guide them through the complexities of regulations, while auditors provide an independent assessment of their compliance efforts.

Building a Secure Foundation

The new programs you’ve created are intended to protect our communities. Specifically, they tackle the challenges posed by third-party risks, the global nature of today’s workforce, COVID-19’s effects on our workforce, labor shortages, and cyberattacks. These initiatives are essential not just for operational resilience, but to safeguard sensitive, public-facing data.

Putting money into compliance now provides a stronger brand foundation. This action creates the certainty needed for industry innovation to prosper and establishes confidence for American consumers. Compliance should not be viewed merely as a cost; it’s an investment in long-term sustainability and reputation.

Auditors bring transparency and integrity to the compliance process, ensuring confidence and trust in compliance operations. They help businesses understand how they can meet the standards and where they might be falling short and need to improve. Despite all good intentions, at the end of the day, it’s the auditor that will ultimately decide whether or not a business is in compliance. Their assessment is essential for showing progress or a lack thereof in regulatory compliance to regulators and key stakeholders.

Know the regulatory environment and take strong protective steps. By doing the hard work of growing a culture of compliance, businesses can reduce risk, increase trust and prosper in a rapidly changing global economy.