Risk Management Framework

Purpose:

The purpose of this Risk Management Framework is to identify and address potential risks associated with the Data Operating Model (DOM). By proactively managing these risks, BMT can ensure the continuity, security, and compliance of its data operations, reinforcing stakeholder trust and the reliability of data-driven decision-making.

Key Risks and Mitigation Strategies:

Data Security and Privacy

  • Risks: Risks include potential data breaches, unauthorised access, and accidental data exposure, which could lead to regulatory fines, reputational damage, and operational disruption.
  • Mitigation: Implement regular security audits, robust encryption protocols, and role-based access controls (RBAC). Quarterly compliance reviews ensure that data policies align with evolving regulatory requirements.
  • Response Plan: A structured incident response plan, including timely notifications, isolation of affected systems, and rapid mitigation, is in place to handle security incidents efficiently.

System Downtime and Resilience

  • Risks: System downtimes, particularly affecting myBMT or data ingestion processes, could disrupt data access and delay key business functions.
  • Mitigation: Establish resilience planning through redundant infrastructure, including failover systems and automated backup processes. Cloud-based scaling capabilities provide an additional buffer to maintain uptime during high demand.
  • Response Plan: Downtime risk is addressed through a critical response plan, defining steps for immediate technical and communications response, stakeholder notification, and service restoration.

Compliance with Data Regulations

  • Risks: Non-compliance with data protection laws (e.g., GDPR) or internal data policies could result in penalties and damage to stakeholder trust.
  • Mitigation: BMT implements compliance protocols that monitor data handling and retention policies. This includes automatic deletion of outdated or non-compliant data and regular updates to align with the latest regulatory changes.
  • Response Plan: Compliance risks are managed through a periodic compliance assessment. Non-compliant data practices trigger an immediate review and corrective action process led by compliance and data governance officers.

Contingency Planning for High-Risk Scenarios:

For high-risk scenarios, BMT’s contingency plan includes the following stages:

  1. Identification: Rapid identification and categorisation of the incident by priority level.
  2. Incident Response: Activation of predefined response teams with clear roles, from IT for technical containment to communications for external and internal notifications.
  3. Resolution and Recovery: Swift problem-solving measures, including data restoration, system backups, or security patching as needed.
  4. Post-Incident Review: Detailed analysis of incident causes and effectiveness of response, leading to refined mitigation strategies and updated protocols.

Data Protection Impact Assessments

DPIAs are a core component of BMT’s privacy risk management strategy. For any new data processing or changes involving sensitive or high-risk data, DPIAs will be conducted to evaluate privacy risks, design mitigating measures, and ensure compliance with regulatory standards. This proactive approach to data privacy protects individuals’ rights, enhances trust, and aligns with BMT’s commitment to responsible data management.

This structured approach to risk management reinforces BMT’s commitment to secure, compliant, and resilient data operations, supporting both operational stability and long-term organisational trust.

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