A few weeks ago, we explored managing risks arising from situations of a delicate nature that cannot be widely disclosed within the enterprise. Because the conventional risk management apparatus — plans, meetings, publication, review and approval — is likely to lead to inappropriate disclosure of sensitive personal information, either such risks are not managed properly, or sensitive personal information is disclosed inappropriately or even illegally.
Let's examine what we would need to do to manage these risks while maintaining an appropriate level of confidentiality.
- Confidentiality infrastructure
- Whatever infrastructure we deploy must be capable of maintaining the confidentiality of sensitive personal information. It's likely that we need a tiered structure for access to personnel-sensitive risk management information. When designing or modifying procedures for managing personnel-sensitive risks, experts in management, security, risk management, and human resources must be involved.
- Multi-part risk plans
- Because some parts of a given risk plan could contain sensitive information, those parts might have to be separated and have controlled access. The number of controlled-access components of a risk plan could depend on the individuals who present personnel-sensitive risks. For instance, in a need-to-know based system, if risks associated with two people are involved and they have different supervisors, we might need independently confidential risk plan components for the two personnel-sensitive risks.
- Access for project managers and sponsors
- For a given project, the project manager and sponsor must have full access to risk management artifacts. To develop and manage their risk plan, they might need access to personnel-sensitive information not normally available to them. This could require adjustment of existing policies.
- Confidential risk reviews for personnel-sensitive risks
- Currently, It's likely that we need a tiered
structure for controlled access
to personnel-sensitive risk
management informationrisk plan review is usually conducted without regard to personnel confidentiality. That process can continue for the enterprise-public portions of risk plans, but the personnel-sensitive components must be reviewed in a confidential manner.
- Confidential budgeting and resource allocation
- Components of project budgets and resource allocation plans intended to cover personnel-sensitive risks can remain enterprise-public, but the documents justifying these budgets and allocations are likely to be confidential and have controlled access, in parallel with the risk plans that drive them.
- Since the people involved in these procedures include some who are unfamiliar with procedures for maintaining confidentiality of personnel matters, training in personnel confidentiality is probably required. And since many of those already familiar with personnel matters are probably unfamiliar with the ways of risk management, they might also require some training.
Because the set of people with access to a given controlled-access document or decision can vary with the content of the document or decision, the requirement for confidentiality of some risk plan components can become cumbersome. But the alternatives — either non-compliance with regulations or poor risk management or both — is worse. First in this series Top Next Issue
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