Dr. Darren Death - Chief Information Security Officer of the Export-Import Bank, is a thought leader with a passion for exploring the integration of technology and work culture.

This is the second in a three-part series on the Foundations of Trusted Operations: Cybersecurity, Privacy, and AI Governance.


Introduction

At EXIM, trust is built through consistent, behind-the-scenes execution. Cybersecurity, privacy, and AI governance—the foundations—are not abstract concepts. They are operational responsibilities that determine whether systems can be defended, whether data is managed with discipline, and whether emerging technologies can be adopted without introducing new risk. Agencies that treat these areas with the seriousness they require build trust over time. Those that do not will continually respond to failures that could have been avoided.

Cybersecurity, privacy, and AI are interconnected: a weakness in one threatens the others. Excelling in all three is essential for modernization, engagement, and resilience. They underpin stability, continuity, and organizational credibility, and should be treated as core elements of mission readiness rather than peripheral functions.

Read Part 1 - Cybersecurity: Sustained Readiness, Not One-Time Compliance


Part Two - Privacy: Data Stewardship as a Strategic Function

In the federal context, privacy means managing the collection and use of personally identifiable information with discipline. Agencies must know what privacy data they collect, why they collect it, whether it’s necessary, and how long it should be retained. If the data isn’t needed to meet a documented and authorized purpose, it shouldn’t be collected. When oversight lapses, data may accumulate without adequate justification, be repurposed beyond its intended use, and consequently increase both the risk to individuals from unnecessary exposure or misuse and the agency’s overall risk profile.

Privacy considerations are most effectively addressed when incorporated into the planning and decision-making phases of system development, rather than being implemented later. This involves assessing systems prior to deployment, ensuring that privacy data collection aligns with clearly defined and authorized objectives, and ceasing data collection when it is no longer required for those purposes. Data retention periods should correspond to mission requirements and statutory regulations, and their enforcement should be monitored. Transparency facilitates accountability by describing what data is collected, the reasons for its collection, how it is used, and when it is deleted.

EXIM incorporates privacy considerations into its operational reviews, procurement activities, and system evaluations. In-depth reviews are conducted to confirm that systems operate according to established privacy requirements. The process includes validating that data collection matches authorized purposes, removing unnecessary data, and ensuring data flows are documented and managed. Privacy measures are verified rather than assumed. We align privacy standards with practical use cases and proactively address instances where applications collect excessive data or workflows introduce unnecessary data exposure. By maintaining this comprehensive approach to privacy, EXIM reinforces its position as a dependable partner, fully aware that our credibility is intrinsically linked to the responsible management of entrusted data.


Part 3 (AI Governance: Structure Before Adoption) is coming soon!