GDPR – Taking Stock

With a couple of months to go until GDPR becomes law, how far up (or down) the Information Commissioners 12 steps are you from compliance?

We would like to give some practical guidance and advice, as well as share our experience to date. Projecting aren’t compliance experts (and don’t pretend to be) but our experience recently has demonstrated that, as with most other compliance projects, the practical application of the regulations requires an operational brain with a compliance awareness and that’s where our clients have been utilising Projecting.

So, here are our top tips:

  • Having a clear Data Policy that covers clients, employees, and vendors
  • Communicate clearly with all of these groups on their rights and data retention procedures
  • Take the opportunity to assess and clean up personal data repositories and anywhere else you keep personal data internally
  • Use this as a marketing opportunity to affirm data security with your clients
  • Document your impact assessment fully, i.e. in and out of scope regulations
  • Be clear about being a data controller, data processor or both
  • You may never get an exhaustive list of the business areas that are impacted, and which functions, but keep communicating and importantly, training, and you will reduce the risk of gaps · Utilise the Information Commissioners website (ICO)
  • Don’t be distracted by some of the esoteric impacts suggested, e.g. business cards – stay principle focused

So, we haven’t provided all the answers, and would never hope to, but rather than be as prescriptive as a management consultant, we want to share the pragmatic and not the enigmatic. As with all regulatory projects, we hope that this will assist in putting context and focus on the GDPR project you are undertaking.

And it won’t surprise you to know that we are covering all of the above in our own, internal, Projecting GDPR project!

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I’ve Started So I’ll Finish

Have you ever been on a project or programme where there is a change of project or programme manager part-way through?

In an ideal world you would have the same project manager from start to finish, but the reality is that this doesn’t always happen. It might be that the PM becomes disenfranchised or demotivated, the project might change direction, the skills needed through the project lifecycle might differ, or the project manager may simply be the wrong fit.

Whatever your role on a project – from business sponsor to business analyst – this is something that you will have to deal with. It can be easy to feel let down if someone leaves but the project show must go on. When it does happen, you should not be surprised but you should be prepared. That is also true if you are the project or programme manager that is moving on.

We take a 4-step approach:

  1. Anticipate it. If the project or programme is particularly long (over 18 months), complex, there is a lot of travel, hours are long, and/or the pressure is high, experience says that the likelihood of a change in personnel is higher
  2. Plan for it. At the outset think about the skills and experience needed for the duration of the project or programme. For example:
    1. Beginning: ability to take disparate views, vague objectives, unclear resource requirements, and mould them in to a functioning project
    2. Middle: build and keep momentum, maintain morale, manage issues and changes, and keep driving the project forward
    3. End: ramp up the pressure, cope with deadline changes/replanning, unstick showstoppers, and get it over the line
  3. Discuss it. If you are thinking of leaving (or thinking that someone should leave!) discuss it. The issues may not be resolvable, e.g. by a change of role, but at least you can create an exit plan that works for all parties
  4. Seize it. Every change is an opportunity. It can create the opportunity to re-evaluation an entire project and it can be the trigger for implementing beneficial changes

Also consider the psychological aspect. The “classic change curve” describes the emotions that accompany change – from excitement and expectation at the beginning, through despair when the going gets tough, to acceptance and positivity towards the end. An awareness of which stage you are at will help in anticipating issues and managing them.

Last, but not least, what about the project or programme manager who is coming in half-way through? They are often expected to understand the project, personalities, politics, culture, and history in days when it really takes weeks (usually months). Everyone wants the project manager to get up to speed quickly so they can start delivering but they must be given the opportunity to do so. That means time, access to the right people, and as much knowledge transfer as you can muster. If you are using the opportunity to, for example, change the project structure then it makes it easier if this is complete before the new person starts (unless you want them to design and implement it).

None of the above means that we should go in to every project expecting the PM (particularly if you are the PM) not to make it to the end. Everyone wants to see it through. But change does happen, and you should be prepared.

In our next article, “Project Orienteering” we’ll be discussing how to navigate your way through projects when you don’t know where you are going, how to get there, and everything keeps changing.

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