With the help of Venable Blue, a multinational company was empowered to respond efficiently to regulator assessment requests with upgraded tooling systems.
When the client, a multinational technology company, faced legal, financial, and reputational risks due to inadequate tooling for responding to regulator assessment requests, it turned to Venable Blue. Leveraging our experience in partnering with third-party assessors, Venable Blue worked to upgrade and enhance the client’s tooling systems to make data collection more granular, consistent, and accessible. From assessing quality assurance processes to enacting technical production changes, Venable Blue proposed both quick and long-term solutions to reduce risk, empower proactive issue mitigation, and enhance trust between the client and assessors.
The Issue: Inadequate Tooling Systems Create an Undue Burden for a Technology Company
The client had been subjected to several government assessments and audits. While the company had tooling that tracked data points essential to daily business operations and privacy commitments, the client began to recognize the inadequacies of its existing tooling operations as audit requests trickled in.
Because of its limited granularity and freeform inputs, the data lacked the detail and consistency necessary to meet assessor requests, and such limitations were creating risk for the company. The client was expending significant time, ad hoc, to collect the necessary information manually and was concerned with its accuracy and with the need to provide it to external stakeholders.
Concerned about the potential legal, reputational, and financial risks associated with inadequate tooling, the client was ready to build more robust systems and policies and sought Venable Blue for our forward-thinking privacy experience, experience with identifying tooling gaps, and history working with assessors.
Venable Blue Response
The client was already in the midst of an assessor audit when Venable Blue was brought in. Keen to address immediate needs while developing strategic and robust long-term solutions, our team analyzed the client’s multiple, different tools to understand their capabilities and to learn what evidence the assessor would require.
To address ongoing assessor requests, we developed a multifaceted quality assurance (QA) process and helped craft responses to assessor questions in language designed to mitigate risks. Internally, our team created a robust QA process to review all audit request responses, including the data exports from the tooling systems that were to be provided to the assessor, enabling them to mitigate anomalies and edge cases. Venable Blue also helped the client develop QA processes within its own business operations. This assessor-facing QA process helped demonstrate that the client maintained sound and diligent processes.
For longer-term solutions, Venable Blue developed process maps outlining how staff interacted with and input data into the tools. In conducting gap analyses and identifying issues that needed to be addressed, the ability for targeted fixes arose. By bringing together client stakeholders such as engineers, product managers, and policy and legal teams, we not only bridged the gap between cross-functional client teams, but also established project plans for repairing tooling functions, key milestones, and tooling function owners. Venable Blue also developed a robust set of training materials and resources to educate employees on using the tool in a compliant way. We also established new lines of communication among stakeholders, which brought consistency to the process. Even when faced with limited technical client resources, our team was able to put in place mechanisms for making business cases and for streamlining high-impact, audit-necessitated technical change requests.
As functionality for data collection was developed, the Blue team conducted validation efforts to ensure it would meet assessor needs. We also developed standard operating procedures to equip engineers to make changes swiftly in the future. By utilizing our understanding of the type of information the assessor would require, our team was able to propose ways that the client’s tooling efforts would be viable in the near term and could be scaled as their operations grow.
Venable Blue’s efforts ultimately built more confidence between the client and the assessor. By establishing more robust tooling and data collection, the client was able to identify product gaps internally and earlier, allowing them to mitigate issues proactively. This, coupled with the client’s newfound ability to determine and resolve edge cases that an assessor may eventually flag, led to greater trust by the assessor in the client’s commitment to product integrity.
How We Can Help You
When your organization is faced with regulatory inquiries and assessors, the Venable Blue team can help. Whether it’s assisting in drafting one-off responses for immediate use or in developing long-term solutions to mitigate risk, our analysts have extensive knowledge of how to best engage with, respond to, and build trust with assessors. Learn more here.