The need for a foundation of privacy in organizations is imperative. As data becomes more valuable, data breaches and other hacks are on the rise, leading to massive losses of customer trust, damage to multi-billion dollar brands, hefty fines from regulators, and legal settlements.
To tackle this challenge, many companies have deployed what is known as ‘Security by Design’ to drive systemic and cultural improvements in cybersecurity. Now, organizations should apply the same approach to Privacy by Design — a systematic, automated, early-stage approach that treats data privacy as an integral part of all business activities.
Here are six key steps an organization should take to adopt Privacy by Design:
1. Embed privacy procedures early.
Privacy considerations can’t be “bolted on” to business processes a week before launch. Organizations must start integrating procedures earlier, so product development, design and other business teams are sensitive to how data can be legally collected, encrypted, and stored.
National regulations may vary by market, so customers in certain places need to know they can opt out of data collection or have the right to review files. An early-stage approach allows time to ensure customers’ consent and other regulations. Organizations should integrate privacy teams into product development at an early stage, make sure any business operation with access to customer data is paired with a privacy expert, and encourage product teams to recognize privacy as a feature, not an obstacle to functionality or other objectives.
2. Automate as much as possible.
Privacy by Design architecture must involve automation. Automated tools can regularly monitor how data is handled and whether the proper regulations are followed. It can also respond quickly to customer requests for data review and deletion, as well as regulator requests to confirm records of processing.
If customers must consent to data collection, an automated system can validate their consent before the data is processed further. Semi-automated or manual processes, such as customer requests for data deletion, can now be fully automated, freeing up staff to focus on special situations, like privacy incident responses. Specially trained teams can prioritize mitigating bigger risks while automation takes care of the little things. It’s important to integrate automation into key functions like consent collection, data storage, data marking, and customer requests for data review/deletion and never abandon commitments to privacy standards, even when the data is no longer required.
3. Foster a culture of privacy.
In any organization, culture will determine the success of Privacy by Design. Employees should feel comfortable and encouraged to ask questions about privacy procedures, risks, and their part in the organization’s larger privacy mission. With a collective understanding of privacy risks and why certain procedures matter, the company’s policies work better overall. Privacy should be championed as a business goal and standards a part of learning curriculum for all parties.
Even if the business claims privacy is a priority and core value, they still need an established workplace culture that truly understands and values privacy and mindfulness of it.
4. Engage the C-suite.
Privacy By Design touches talent from the bottom to the top of the hierarchy. To effect change on a company-wide scale, C-suite leaders need to be not only on board with the privacy strategy, but also engaged and understanding it. According to TCS’ Risk & Cybersecurity Study conducted with 600+ CISOs and CROs, data protection and privacy is the highest priority for information security leaders and a main investment focus for the next few years.
Privacy experts should educate the C-suite on risks, making sure to emphasize privacy as a strategic business goal. This way, the top executives understand how central privacy is and hold it to a high standard. Privacy in tow becomes the fabric of strategic goals and deepens customer relationships.
5. Be customer-centric.
Place the customer — whose identity, data and other valuable information is at stake — at the center of key decisions. Make privacy a default position, build in appropriate, regular alerts to users related to privacy options, and design all privacy systems with the user’s ease and security top of mind.
6. Put specialized people behind your policy.
As with any policy, it matters who implements it. An essential part of any privacy agenda is a team of leaders, specialists, and others who understand regulatory requirements and how to build privacy solutions. This can’t be done through training and seminars alone. As seen with Security by Design, developers don’t have a natural sensitivity towards certain cyber threats. For Privacy by Design, the approach deserves a dedicated, specially trained group of professionals to ensure regulations are followed and data remains secure. These professionals can be attained by seeking out, recruiting and developing trained privacy experts to identify vulnerabilities and monitor regulations. Privacy awareness should be an essential competency for incoming team members, especially roles in product development, customer care, and leadership.