Data privacy is not only a legal and technical issue, but also a moral and ethical one. If your organization is committed to social and economic justice, you need to align your data privacy monitoring with your values and mission. In this article, you will learn how to do that by following these steps:
Before you can monitor your data privacy practices, you need to understand what data you collect, how you use it, and who you share it with. You also need to identify the risks and benefits of your data activities for your stakeholders, such as your customers, employees, partners, and communities. You can use tools like data mapping, data protection impact assessment, and data ethics frameworks to help you with this step.
Companies need to realize that collected data has cost. They need to understand that for every bit of personal data they collect, there is a cost to management, storage, and even deletion. Plus, there is the cost of a breach if it happens. Not to mention, trust issues when you collect more data than necessary. Therefore, companies need to assess what they collect, and why they collect it and even ask "Do we need this?". All data that is collected must be formally assessed for necessity via DPIA and each identified risk managed via a risk register.
Understand the types of data your organization collects and processes. Identify sensitive information related to social and economic factors, such as demographic details, income levels, or employment data. Minimize the collection of unnecessary data. Only collect and process information that is directly relevant to your organization's mission and objectives related to social and economic justice. Clearly communicate to individuals why and how their data is being collected and processed, emphasizing the organization's commitment to social and economic justice. Provide accessible privacy policies that outline data usage practices.
Based on your data assessment, you need to establish your data privacy goals and policies that reflect your organization's social and economic justice commitment. For example, you may want to ensure that your data collection and processing are fair, transparent, accountable, and respectful of human rights. You may also want to adopt standards and principles like the GDPR, the CCPA, or the UN Guiding Principles on Business and Human Rights. You should document your data privacy goals and policies and communicate them to your stakeholders.
In life, it is important to know where you are headed. Similarly, in privacy, a company needs to establish a privacy approach, and objectives /goals and create a policy that states what the company aspires to do in the context of privacy. With clients I work with, we start by looking at current and future business strategies. Basis this, we define a privacy strategy and then identify principles of privacy that the company wants to be known for. All this sets a good basis for writing a data privacy policy which is then aligned with key stakeholders.
To achieve your data privacy goals and policies, you need to implement appropriate controls and measures to protect your data and comply with the relevant laws and regulations. You may need to use technical solutions like encryption, anonymization, pseudonymization, or data minimization. You may also need to use organizational solutions like training, awareness, consent, or contracts. You should monitor the effectiveness and performance of your data privacy controls and measures regularly.
Once you have defined privacy principles and a company privacy policy, it becomes a foundation for the key controls that departments will be measured against. And, for each control, privacy champions should define measures that they would implement. From an accountability perspective, with my clients, we create a Privacy Control Framework that each department would need to self-certify against on an annual basis. Such an approach makes sure that everyone knows what is expected and does exactly that. This is a practical way of implementing privacy.
To align your data privacy monitoring with your social and economic justice commitment, you need to review the outcomes and impacts of your data activities on your stakeholders and society. You should collect feedback, evidence, and indicators to measure how your data privacy practices affect the rights, interests, and well-being of your stakeholders. You should also consider the potential unintended or negative consequences of your data activities, such as discrimination, bias, or harm.
To demonstrate your data privacy monitoring and alignment, you need to report your data privacy results and actions to your stakeholders and the public. You should be transparent and accountable about how you collect, use, and share data, and how you protect and respect data privacy. You should also disclose your data privacy challenges, gaps, and improvements, and how you address them. You can use tools like data privacy reports, dashboards, or certificates to communicate your data privacy results and actions.
To sustain your data privacy monitoring and alignment, you need to improve your data privacy practices and culture continuously. You should review and update your data privacy goals, policies, controls, measures, outcomes, impacts, results, and actions regularly. You should also foster a data privacy culture that values and promotes social and economic justice within your organization and beyond. You can use tools like data privacy audits, reviews, or awards to support your data privacy improvement.
I would like to emphasize two more considerations: 1. Customer Communication: ** Be transparent with customers about data usage and privacy measures. **Seek feedback and demonstrate a commitment to protecting customer privacy. 2. Risk Management: ** Identify potential privacy risks and implement measures to mitigate them. ** Align risk management strategies with overall business risk appetite.