If there are issues at your organization that haunt you, and you’re aware of them, it’s time to lay out a plan for addressing them. These issues should be documented on your risk assessment, given a risk ranking and ultimately should flow through to your work plan and flow downstream to the company’s audit plan and into ongoing monitoring processes.

The Circle of Known Risks

Demonstrated in the model below, “known risks” should flow through the “risk assessment/ranking process” to a “decision point,” where the organization determines how to address the risk.

At that critical juncture, it’s time to decide whether you’re going to accept, avoid, control or transfer the risk to a third party. The outcome from the “decision point” establishes what will flow to your work plan. Then it’s on to the audit plan and ongoing monitoring processes. Findings from audits and ongoing monitoring processes then become known issues/risks and then flow back through the same process. It’s cyclical.

Talk to Legal

It’s important to talk to your partners in legal prior to documenting known issues. They will be able to guide you on what to document related to known issues and risks; when something may be put under legal protection such as privilege—for example, work product in anticipation of litigation—and what process to follow before providing this documentation internally or externally—for example, any disclaimers that need to be included, such as “Confidential—For Internal Use Only.” Such information cannot be further disseminated without written legal approval. Carefully think through whom—internally—needs to have access to this type of information, and keep that group limited. One way of approaching internal access is to limit it to those who “need to know.”

Accept, Avoid, Control or Transfer the Risk?

As we all know, there is never enough time, resources or budget to tackle everything at once. As such, the risk score or ranking becomes your map for what to tackle in order of priority. The next step is to figure out what you are going to do about the issues or risks. Are you going to accept the risk, avoid the risk, control the risk or transfer the risk to a third party? If you choose to control the risk, those items will move to your work plan to be addressed.

Important items to make sure that you are documenting are:

  • any estimations of cost;
  • the business area that is funding the project or any agreements related to budgeting;
  • the business owners—senior leaders as well as the people that will be taking on the actual work;
  • approvers;
  • description of the risk to be addressed;
  • any requirements identified that need to be addressed during the project interim controls that are being implemented until the risk can be fully mitigated, and
  • target dates.

Why is this helpful? Because going through this process helps you work out your own plan but also may serve as evidence for a regulator that you are focused on the right issues or risks and that you have a plan for addressing them. Being able to show a regulator that you were aware of the risk, have performed a risk assessment and have a plan for addressing the risk should work to your advantage.

Use your documentation to keep leadership informed on risks and to gain resources and budget dollars to address the top priorities. Also, use this documentation to keep them informed of the work you are planning, the work that you are not able to get to and to make sure they are in agreement with where you are focused.

Besides helping your case should a regulator come knocking, documenting your action plan for known issues and risks is extremely important for all organizations because following this simple model will help ensure that you are focused on the right things, that you are applying your resources to the right projects and that leadership stays informed about the important work that you are doing within your organization.

Written By

Deidre Rodriguez, CIPP/US


If you want to comment on this post, you need to login.


Board of Directors

See the esteemed group of leaders shaping the future of the IAPP.

Contact Us

Need someone to talk to? We’re here for you.

IAPP Staff

Looking for someone specific? Visit the staff directory.

Learn more about the IAPP»

Daily Dashboard

The day’s top stories from around the world

Privacy Perspectives

Where the real conversations in privacy happen

The Privacy Advisor

Original reporting and feature articles on the latest privacy developments

Privacy Tracker

Alerts and legal analysis of legislative trends

Privacy Tech

Exploring the technology of privacy

Canada Dashboard Digest

A roundup of the top Canadian privacy news

Europe Data Protection Digest

A roundup of the top European data protection news

Asia-Pacific Dashboard Digest

A roundup of the top privacy news from the Asia-Pacific region

Latin America Dashboard Digest

A roundup of the top privacy news from Latin America

IAPP Westin Research Center

Original works. Groundbreaking research. Emerging scholars.

Get more News »

Find a KnowledgeNet Chapter Near You

Network and talk privacy at IAPP KnowledgeNet meetings, taking place worldwide.

Women Leading Privacy

Events, volunteer opportunities and more designed to help you give and get career support and expand your network.

IAPP Job Board

Looking for a new challenge, or need to hire your next privacy pro? The IAPP Job Board is the answer.

Join the Privacy List

Have ideas? Need advice? Subscribe to the Privacy List. It’s crowdsourcing, with an exceptional crowd.

Find more ways to Connect »

Find a Privacy Training Class

Two-day privacy training classes are held around the world. See the complete schedule now.

Online Privacy Training

Build your knowledge. The privacy know-how you need is just a click away.

The Training Post—Can’t-Miss Training Updates

Subscribe now to get the latest alerts on training opportunities around the world.

New Web Conferences Added!

See our list of upcoming web conferences. Just log on, listen in and learn!

Train Your Staff

Get your team up to speed on privacy by bringing IAPP training to your organization.

Learn more »

CIPP Certification

The global standard for the go-to person for privacy laws, regulations and frameworks

CIPM Certification

The first and only privacy certification for professionals who manage day-to-day operations

CIPT Certification

The industry benchmark for IT professionals worldwide to validate their knowledge of privacy requirements

Certify Your Staff

Find out how you can bring the world’s only globally recognized privacy certification to a group in your organization.

Learn more about IAPP certification »

Get Close-up

Looking for tools and info on a hot topic? Our close-up pages organize it for you in one easy-to-find place.

Where's Your DPA?

Our interactive DPA locator helps you find data protection authorities and summary of law by country.

IAPP Westin Research Center

See the latest original research from the IAPP Westin fellows.

Looking for Certification Study Resources?

Find out what you need to prepare for your exams

More Resources »

GDPR Comprehensive: Spots Going Fast

With the top minds in the field leading this exceptional program, it's no wonder it's filling quickly. Register now to secure your spot.

Be Part of Something Big: Join the Summit

Registration is open for the Global Privacy Summit 2016. Discounted early bird rates available for a short time, register today!

Data Protection Intensive Returns to London

Registration is now open for the IAPP Europe Data Protection Intensive in London. Check out the program!

P.S.R. Call for Speakers Open!

P.S.R. is THE privacy + cloud security event of the year, and you can take a leading role. Propose a session for this year's program.

Sponsor an Event

Increase visibility for your organization—check out sponsorship opportunities today.

Exhibit at an Event

Put your brand in front of the largest gatherings of privacy pros in the world. Learn more.

More Conferences »

Become a Member

Start taking advantage of the many IAPP member benefits today

Corporate Members

See our list of high-profile corporate members—and find out why you should become one, too

Renew Your Membership

Don’t miss out for a minute—continue accessing your benefits

Join the IAPP»