SITUATION
A global technology company in Silicon Valley established a privacy program to meet the requirements of a Federal Trade Commission (FTC) Stipulated Order (Order) to protect privacy, confidentiality, and integrity of Covered Information. As a part of the privacy program, an in-house tool was developed to better aggregate and utilize complex data sets and streamline collaboration across various business partners and cross-functional teams. As the tool went live earlier this year, processes had not been standardized and very little documentation existed that could be used by a growing team.
OUR ROLE
FTI was engaged to evaluate the current state processes, clarify policies, improve processes, and develop a scalable framework for leveraging the in-house tool. This included performing shadowing sessions, working with stakeholders to gather relevant information, evaluating documentation to identify gaps or areas of improvement, assessing the maturity of the program, and developing updated runbooks, guidebooks, and ultimately a framework to be leveraged across the company on various business partnerships, processes, and methodologies.
OUR IMPACT
FTI helped enhance the company’s audit posture and their ability to meet the requirements of the FTC Order through the documentation and standardization of internal processes. The level of expertise demonstrated by FTI heavily contributed to the client’s decision to extend the existing contract for a follow-on phase and request an additional contract for targeted Third-Party domain maturity assistance. In this next phase, FTI will work to remediate complex root issues, formalize accountability, and ensure continuous improvement of the privacy program to achieve FTC Order requirements.