Technical Writing | General Data Protection Regulations

GDPR

On the 25th May 2018, the new General Data Protection Regulations (GDPR) came into force.

Companies outside the EU

If your Company actively trades within the EU and stores, processes or shares EU citizens’ data, then GDPR does apply to you.

Compliance and documentation

One of the primary rules is that under GDPR Process activities MUST be documented.

Companies are required to maintain a set of Policy, Process and Plan (PPP) documentation to ensure you have evidence to support your claims should the ICO investigate any complaint or breach of data.

Note that the Information Commissioners Office (ICO) could demand to see the written documents

What do you need to consider?

As a technical writer, with experience writing compliance documentation, what can I tell you?

If you are still struggling to start

My Blogs are clear, writing one document, when there is a substantial list to be completed from scratch to sign off is a lengthy process. Even if your department has documents that can be reused, it will still take a long time. Compliance projects are manually intensive and documenting GDPR will need dedicated resources.

My experience could be necessary to help you write and manage those documents. The sooner you contact me, the sooner we can start the road to compliance.

  • Create a standard template with – Statement, In Scope, Version Control, Change History, Distribution Lists, Roles and Responsibilities
  • All PPPs must adhere to GDPR – include in the document ‘The purpose of the document’, ‘The Scope’ and add a list of the GDPR compliances relevant to the PPP you are writing and explain the WHY the company are complying along with the HOW the company will comply.
  • The documentation must be relevant to your business. Generic documentation outlining a PPP will NOT suffice
  • Complete the documentation – do not start and leave a document incomplete then sign off; an incomplete document could fail a Compliance Audit
  • Maintain the detail – do not half explain a process or policy
  • Structure the documentation to avoid duplicating information over several documents
  • That the documentation may need to be ISO 27001 compliant
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Technical Writing | Hire a Technical Writer sooner, rather than later

As a Technical Writer with over Twenty Years of experience, I have a question for Project Manager. Have you ever planned a project (PCI, GDPR, ISO27001, ITIL) where documentation is critical; if so, how did it go? Crucially, did the project deliver ALL the documentation? If not – do you know why the plan failed?

First: Did you speak to a Technical Writer for a realistic appraisal of the expected outcomes?

Second: was your budget a few pennies short?

A collective failure of technical / process documentation projects is the lack of knowledge and expertise during the planning and discovery phases. Many project managers do NOT grasp the reality of a documentation project.

The planners do not understand the lifecycle of a document. From the initial draft through various reviews and sign-off takes much longer than expected.

If the PM does NOT know the difference between a written process, a documented plan, and the purpose of a policy your project could be in trouble.

How long to write a document? My default answer is “I do not know”. Technical and process documentation depending on the project (PCI, GDPR, Operations, ITIL) will have many requirements and factors which delay the following stages:

      • the information gathering,
      • the writing,
      • review stages, and
      • sign-off.

The likely reality of writing a 30-page A4 process document containing:

      • VISIOs (3 or more) comprising between 10 to 30 steps
      • Process narratives (3 or more) of between 10 to 30 steps
      • Appendixes (2 or more)

Will  take at least 8 – 12 weeks of effort before reaching the review stage. My advice is not to plan such a project without professional help.

Compliance projects such as PCI and GDPR generate a lot of documentation. If you are starting from scratch, the list of required documents could exceed 60 or more.  In timing terms you are looking at 12/18 months of work or more. If you have partially written documents, DO NOT expect timings to diminish to a few months. Your project faces a lengthy overhaul as a technical author will attempt to get the documents into a consistent state. Finally, to succeed there must be management buy in. Without t the TA will struggle to muster the help. Any failures will multiply costs.

Hire a Technical Writer

My advice is this – If you have a project that requires documentation, hire a Technical Writer, not a Business Analyst, for advice from the start of the project, NOT when the end date is in sight and the budget is running out. The TW can highlight issues, risks, and bottlenecks and help you manage expectations within the allocated time assigned to the project.

The Technical writers will need:

    • a week (at least) to assimilate the project
    • Time for training on any tools
    • access to Subject Matter Experts (SMEs)

Add in contingencies for illnesses, holidays and unplanned absences, and the fact a TW could resign from the project at some point.

If the budget and the timelines become fixed (in stone) with multiple documents to complete in a short period, then produce quality, rather than quantity.

To ensure quality, rank the documents across the set:

    1. Required
    2. Nice to have
    3. Not important

Or use The MoSCoW method.

    • M – Must have this requirement to meet the business needs
    • S – Should have this requirement if possible, but project success does not rely on it
    • C – Could have this requirement if it does not affect anything else on the project
    • W – Would like to have this requirement later, but delivery won’t be this time.

Additional Points

    • Travel: Will the TWs need to travel abroad or Nationally.
    • References: Identify any useable archived documentation.
    • Reviews: decide who will review and who will sign off a document
    • Scope: Could there be any changes which will add to, or change the scope of the project

In summary,

Documentation projects fail due to:

    • poor planning
    • the lack of experience and
    • not allowing enough time to complete the documentation.

Finally: If the success of the project depends on the documentation (Disaster Recovery Plan, PCI/DSS, BCP and ITIL) – why do PMs and SMEs allocate so much of the budget to non-documentation resources?

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