New rules, Old roots, Old attitudes

So, today the European Commission is announcing new rules for Data Protection and Privacy in the EU (and the EEA countries and those countries seeking accession to the EU). There is hype and hoopla about the rules and what they mean, particularly for organisations conducting business on-line, companies based outside the EU selling into the EU, standardisation of penalties, and realignment and consolidation of the Regulatory and Enforcement regime.

Oh yeah, and it is being done by Regulation which means the rules will be the same across the EU.

But at its heart the fundamental principles remain the same. Organisations who seek to process personal data of individuals need to make sure that the ‘deal’ is fair. After all, to paraphrase Commissioner Reding’s comments at the DLD conference in Munich earlier this week

Personal information is the currency of the Information Age

And as with all markets where items of value are traded, checks and balances need to be in place to ensure the asset is valued appropriately and treated with care. Hence the focus in the new Regulation on concepts such as Privacy by Design, ensuring appropriate training of staff, specific requirements re: organisational governance and internal controls and clarity of documentation about the meaning, purpose, and methods of use of personal data. There is an economic trade off required to obtain the thing that is of value. That trade off is good management of Personal Data through the life cycle of the Information Asset.

As a Data Governance and Information Quality guy I’m glad to see that the legislators in my third area of passion have finally caught up with the need to ensure organisations have defined Quality Systems with defined decision rights and accountabilities over Information as an Asset.

So, while many of the rules are new, their roots are old. Based on my reading of the version of the Regulation that was leaked just before Christmas revealed a Regulation with one foot in the camp of Fundamental Human Rights (and the trade offs that need to be made there for economic activity to take place) and the other firmly in the camp of Quality Management practices and principles, with a clear focus on creating a Constancy of Purpose in management towards the goal of striking a sensible balance and ensuring a fair deal in the processing of personal data.

And that is where the problem begins.

There is a window now for national governments and the European Parliament to make contributions to the Regulation. Many in national government and the EP will make sensible contributions that will evolve the framework and make it easier to implement in practice.

However, in a month where one Government Minister acted in blissful ignorance of the Data Protection Acts one week, another flew a policy kite that would require an illegal extension in scope of the database being built by the first Minister, and where the unelected officials of the largest City Council in the country appear to be unable to point to the legitimate grounds on which they transferred the personal data of over 100,000 residents to a private company, I hold out little hope of sensible debate and dialogue from the Irish body politic.

In a month where we greeted the year (for the second year in a row) with a story about poor planning of projects involving personal data (both under the stewardship of the same person) I hold out little hope of sensible engagement from the Irish body politic.

And in a month where the reversal of a bad law to control copyright on the Internet (SOPA) after leading websites across the world “went dark” we find a Junior Minister of the Government, in the Department that is in charge of attracting and retaining exactly those companies who opposed the US law, seeking to implement a similar law by Statutory Instrument with no debate or discussion, even after the legal position and EU policy position has changed in relation to Internet blocking, and only the opinions of the dying industry this law would protect seem have been sought in advance, I hold out little hope for the Irish Body Politic not to make an arse of this.

And as for the Irish media… with a few notable exceptions the absence of attention to Data Protection issues (except where it involves embarrassing a Government Minister and the copy can be lifted from this blog) is staggering. So yet again I hold out little hope of sensible engagement.

Adapting to the new Data Protection landscape will require individuals to change their mind set. But I fear that the entrenched attitudes in the body Politic and the traditional media may be such that Ireland (the little nation that faced trade sanctions in 2003 for not implementing Directive 95/46/EC by 1998 as we were required to) will fail to step up to the plate and drive the change in thinking and attitude necessary to achieve sustainable and sustained change in Data Protection practices in Ireland.

W. Edwards Deming wrote in his famous 14 Points for Transformation that it was essential for the transition that organisations “Institute Leadership”. I see precious little leadership in this area from our politicians and only dazzling pin-pricks of illumination from the main stream media. So I must keep my hope guarded in the face of the likely knee jerk reactions against the changes and the almost inevitable white noise of ignorance until the Regulation passes into law with a direct effect sometime in 2014.

Prove me wrong. Please.

Leadership – a follow up post

I had a great response to my post recently about leadership in information quality. Since then I’ve had the opportunity to discuss leadership and aspects of leadership with a number of people, both in person and on d’interwebs. One key trend keeps cropping up… the approach and characteristics of a particular leader may not always be appropriate to the battle at hand and a real leader knows when it is time to pass the torch to someone else.

It was summed up for me very well by an Irish trade union leader who I spoke with last week. In his words:

Any leader who is planning for success should really start planning for succession if they want things to be sustained 

This is the difficult challenge of leadership. Knowing when the time is right for you to pass the baton and, equally as importantly, knowing that the people you are passing the baton too will be able to build on your leadership without appearing simply to be mere managers working solely within parameters you have defined, but instead being leaders in their own right, building on the foundations you have set to create a new vision.

Knowing the time to move on is difficult. It requires the leader to be able to focus both on the problems of today and the challenges of tomorrow and to have sufficient self-awareness to let them judge how well their skills, experience, passion and energy will meet the expectations of tomorrow’s battles.

And this needs to be planned with foresight to ensure you have time to develop your people and drive leaders from the bottom up in your organisation and in your team. Often this requires developing people’s confidence in themselves as much as the confidence others have in them. Inevitably it means letting them pedal the bicycle themselves to prove they can do it.

The plan needs to cover getting the right people on your team, developing them, growing their skills and ‘battle-hardening’ them. It means having a plan to instil the same core beliefs, priorities and passion (in my case for Information Quality) into your future leaders. At the same time you must ensure that they have the ability and capability to think for themselves and build on your example effectively while ensuring continuity and consistency. Above all, to take on the mantle of leadership, and to be effective, your successor needs to have enough credentials and credibility to face down challenges while having sufficient differentiators to avoid being viewed as a puppet of the outgoing leader.

And your last act as leader is to sell your successor to your stakeholders.

While this is true of pretty much any organisation, in my experience it is especially true of an information quality team. Getting your IQ programme started is a challenge that requires certain types of leadership characteristics. Keeping it going and sustaining the gains you make can often require a different leadership style and approach. Knowing when to make the change is a skill in itself, and given the risk of ‘pigeon holing’ that any specialist faces in an organisation, it can often require a move out of the organisation you are in (to elsewhere in the larger business or on to pastures new).

One noted Irish leader I have studied retired recently from a leadership role he had held for almost four decades. He had spent most of the last decade developing the people who are to replace him. They have a track record and credentials in the solutions of the past, have a passion for the issues that are pressing today, and have the vision and ability to lead on the challenges of tomorrow. They are different people to him and the style and approach of the organisation will shift somewhat, but the core elements of the vision this leader established over the last 40 years will remain in place.

That’s leadership.

Next: You’re a Leader – Lead


In a previous post, I wrote about how much of what is being pointed to as the causes of some of our economic woes being grounded in weaknesses in the ‘conventional wisdom’ of management which had been questioned by Quality Management thinkers and which were described by Deming in particular as being “Deadly Diseases”.  I argued that, as part of any long term recovery, we would need to look to proven Quality Management principles for guidance and that the lessons of Quality Management (in particular where it is applied to information products and processes) need to be learned now as part of the necessary change.

In this post, I thought I’d turn my attention to just one of Deming’s 14 Points for Transformation, specifically Deming’s Point 7.

Institute Leadership with the aim of supervising people to help them to do a better jobContinue reading