Ten Steps to a Quality Privacy Program, Part Five: Building an Audit Plan
By Deidre Rodriguez, CIPP/US
The privacy industry continues to become more and more regulated, and organizations need to be prepared for audits by regulators and customers. Having an audit plan is essential. This planning and pre-audit work will make everyone’s lives easier and reduce stress once the audit is announced. Below are a few basic steps that will help you prepare and simplify the audit process.
Identify a core team of individuals that will be responsible for key activities during the audit, including reviewing the audit request, making determinations regarding the audit responses and reviewing/approving documentation prior to providing it to the auditor. This team may include representatives from the privacy office, information security, legal, human resources, corporate security and the internal audit team. This core team will be key decision makers throughout the audit process.
Once you receive the audit request, you will have a very tight timeline in which to pull together anything that is needed. Create a timeline of the activities that need to happen and develop a project plan to prepare the company for the audit. Identify who will be responsible for each activity. Think about pre-audit activities, during-audit activities and post-audit activities that need to take place. Who will greet the auditors, get them the access they need, escort them while on the site? Thinking carefully through details will keep you from scrambling at the last minute. The timeline should include activities such as review of the audit request, communications to leadership informing them of the audit, kickoff meetings with key stakeholders, the collection of information pertaining to the audit and daily meetings with stakeholders. The timeline should walk through all activities that will take place from the moment the notice is received, through the audit finding review, through the corrective action processes down to the lessons-learned session that will take place at the end of the audit process. Be sure to include daily meetings with participants of the audit to ensure that they are making progress on their responsibilities and to ensure that you are aware of any issues as quickly as possible.
Develop a playbook that documents any background information that business partners may need—who is auditing, under what requirement and what will they be auditing; identify the core team, define the roles and responsibilities of each group of participants in the audit; include the timeline and project plan for the audit; insert helpful information that others may not know, such as tips on the interviewing process; provide guidance on format and where data should be placed, any legal disclaimers that need to appear on documentation and overview of review/approval process and who to contact with questions.
Make sure that you do your homework and have as much detailed information on the format, any legal disclaimers that need to be included on documentation and how the auditor wants to receive the information to avoid rework. Writing down all of the details will solidify your plan. You may not be audited right away, and people tend to forget everything that you have told them and panic when they hear the word “audit.” Having this information written down will help keep everyone focused and moving the same direction.
Identify and document the stakeholders that you will be asking to participate in the audit process and define everyone’s roles and responsibilities. Bring all of these players to the table to review the playbook, roles and responsibilities and get their buy-in prior to the audit. This will give everyone the opportunity to ask questions, confirm that any assumptions are correct and identify any gaps in your planning process. Do not forget to include your business associates or downstream vendors in these discussions to make sure that any information that you may need from them can easily be obtained.
For each communication noted on the timeline, create a communication plan and develop draft templates that can be tweaked and easily updated. Identify each communication that may be needed, key messages, whom the target audience is, and go ahead and develop draft templates that can be tweaked and easily updated. Having these communications ready to go will take unnecessary work off your plate during the audit where your time and attention can be focused elsewhere.
Have a map or crosswalk that shows how you comply with each of the compliance requirements. There are governance, risk and compliance tools that are available for purchase that create a map, or you can use a simple spreadsheet. Include the citation and related language regarding the requirement, any policy that the organization follows, any training, communications, related tools, systems, monitoring and ongoing testing that takes place in the organization and shows how you comply.
Perform mock audits. You definitely want to know about any issues now instead of when an auditor has their eyes on you and the clock is ticking. Pay close attention to the quality of the documentation that is provided by the business, the amount of time that it took to collect the information, note any issues or concerns that you have found and develop a formal corrective action plan to address each issue. You still have time to fix things prior to the audit.
Taking the time to pull together a thorough audit plan is smart. It will enable you, leadership and the company to be well prepared for the audit. It will help everyone to be on the same page and reduce confusion during the audit process. Be sure to schedule a regular review of your audit program materials. Develop a plan to keep stakeholders engaged after the initial meeting where you share your playbook and process with them. Engage leadership, and make sure they are aware of the potential for audits and the plan.
You do not want an audit to surprise your leaders. These leaders can help set the tone at the top and help you get the support and resources needed.
Deidre Rodriguez, CIPP/US, has actively been working in privacy compliance for 10 years, including policy development, incident response, advisory support and strategic planning. Currently, Deidre is the director of the Corporate Privacy Office and Regulatory Oversight for WellPoint, Inc.