Setting Up Privacy Committee & Communicating the Policy

After delving into the intricacies of Privacy Policies in our previous discussion, let's now focus on what constitutes an effective privacy policy.

In my view, the logic that applies to any organizational policy also rings true here: the policy must be well-known among the impacted audience, as the consequences of noncompliance can be severe, both materially and commercially.

In today's era, where privacy is a paramount concern, it's increasingly important for organizations to establish a privacy committee within their structure.

Privacy Committee

The size of this committee can vary based on the organization's scale.

• Small Organizations: Smaller entities, with around 5-10 people in each department, may only need one Privacy Manager.
• Large Organizations: Conversely, a larger organization with thousands of employees might find it beneficial to have a Privacy Manager for each department, all reporting to a Central Privacy Manager.

For organizations spread across multiple locations, especially in different countries, appointing data protection officers or privacy managers for localized goals, who then report to a Global Privacy Manager, would be optimal.

To understand what a privacy policy is and its purpose, please refer to my previous post https://bit.ly/3v7snoq.

The first step towards implementing an effective privacy policy is to ensure it is easily understandable and concise.

From the perspective of third-party applications, privacy policies are often lengthy. You might have the option to email the policy for records & review, but when in urgent need of the application, choices seem limited.

This scenario is reminiscent of taking a loan from a bank or financial institute. Traditionally, the paperwork is so extensive that, in dire need, one tends to sign without reading, only to revisit the documents when issues arise. This practice, while necessary for banks or app vendors to communicate their terms fully, leads to overly long documents.

How Long Should the Privacy Policy Be?

Ideally, the policy should be structured to highlight key features prominently at the beginning, with options available to delve into details for those interested.

The goal is for users to grasp the essential points quickly. If unsatisfied, they should explore the details before acceptance. This approach allows users to overview the main points, skipping to the details of particular interest, thus saving time and making informed decisions.

The summary page should succinctly present broad points, with hyperlinks for detailed exploration. Users can accept the overall terms if satisfied, ensuring they're well-informed.

Once established, the policy can be circulated via email to relevant stakeholders, especially external ones like vendors and customers. Regular updates on privacy policy adherence when handling data are crucial.

Communicating to Internal Stakeholders

Effective communication is paramount for internal stakeholders, including:

• Vendors
• Customers
• Employees

Collaboration with the internal communications team and department heads is essential for devising effective communication strategies. It's impractical to distribute lengthy documents and expect adherence.

Implementing a privacy policy necessitates a cultural shift in how personal and client/vendor information is handled.

The communications team should initiate this with:

1. Training of the Teams:Use real examples rather than policy readings.Build small case studies highlighting consequences, such as inadvertent data sharing incidents.

1. Emails:Communicate with concise messages, utilizing images or cartoons for easier consumption.

1. Posters & Postcards:Design visual reminders of the policies for common areas within the office space.

1. Privacy Policy in Common Areas:Display policy highlights in areas frequented by external stakeholders to demonstrate data handling practices.

1. Privacy Training Program:Incorporate privacy education into new hire training programs.

1. Regular Workshops:Conduct department-specific workshops quarterly to reinforce privacy practices.

A very nice example set by my daughter’s school is having placards with state name & capital between the stairs all across the school during the Annual Academic Fair, helps children climb up & revisit state capitals.

Organizations should conduct regular assessments to ensure policies are not only implemented but also adhered to, possibly through questionnaires or mock drills.

Conclusion

Effective communication is key to policy implementation. For internal stakeholders, particularly in human resources and IT, safeguarding sensitive information is a top priority. In our next series, we will explore the initial steps in designing a Privacy Policy and aligning with privacy laws, such as the Indian Digital Personal Data Protection Act 2023.