It’s Never Too Early to Think About Privacy

The collection, use and disclosure of data is increasingly a key issue for businesses of all types, industries, sizes and locations.  Managed well, data can be an important or even critical business asset.  In contrast, a lack of adequate planning and preparation about data privacy and security can have long-term implications for a business, effectively limiting how it can use and share information, and in the worst situations, can result in significant liability and negative publicity.

Companies should consider adopting a privacy by design approach and integrating privacy considerations into their business model as early as possible.  As we have seen recently, even powerhouses like Google face complications when implementing privacy policy changes once data has already been compiled.  Of course, even the most well constructed privacy programs will likely need to adjust over time as laws, technology and business practices change, but planning ahead may help to avoid major overhauls that may result in consumer backlash or worse.

Privacy planning involves far more than drafting and posting a privacy policy.  Depending upon the nature of the business and the types of data that it uses, attention may need to be directed to: (i) disclosures made to consumers and other data subjects; (ii) internal policies and training; (iii) information security; (iv) agreements with vendors and service providers; (v) data sharing arrangements; and (vi) marketing initiatives and other key areas.

Effective privacy planning is not a quick or easy task.  However, taking the time to think about privacy early on and developing a comprehensive strategy to guide the company through its lifecycle will undoubtedly pay off.

This post on Compliance and Data Security was authored by Jacqueline Klosek.

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