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Crafting a Robust Privacy Plan for Your Business

Learn how to develop a comprehensive privacy policy that covers every aspect of handling personal information, ensuring clarity, consistency, and ease for customers. Explore strategies for marketing, customer service, and public relations to maintain trust and comply with regulations.

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Crafting a Robust Privacy Plan for Your Business

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  1. Les SeagravesEarthLink, Inc.

  2. Beyond Your Privacy Policy: Developing a Comprehensive Privacy Plan • Les Seagraves, CIPP • VP, Chief Privacy Officer & Asst. General Counsel • EarthLink, Inc.

  3. Your Policy Should Cover: • Everything you do with personal information and what choices customers have • Helps to have External and Internal policies the same • Plan for the future

  4. Policy is great, now what ? • Everything else you do or say can become “policy” • Everywhere you deal with personal information needs to be part of a plan • Follow the data

  5. Following the Data • Advertising • Communicating to Non-Customers • Sign Up/Purchase • Using the Product or Service • Communicating to Customers • Customer Interaction • Ending the Relationship

  6. Everything about Privacy should be: • Easy • Obvious • Consistent

  7. Website • Collect information? • What do you say about it at the time of collection? (Obvious) • Choices? (Easy) • What actually happens? • Consistent with privacy policy? • 3rd Party Links? (Obvious)

  8. Marketing • Are there claims about information use? Should there be? • Clear what information is required? • Contests?

  9. Email to customers • Big issue because of different internal groups and uses • Effective Opt-out? (Easy) • Surveys • Categorize information = easy and obvious

  10. Registration • Account for every piece of information coming in • Storage • Paper records = destruction

  11. Customer Service • Real time interaction with a customer • Need good rules for what and how information is collected and used • Ask for MMN? password? (Consistent) • Warnings to customers? • Phishing?

  12. Public Relations • PR and Managers need to understand the intricacies of your policy • CEO speeches – be careful • Blogs

  13. Plan for a mess • What happens during a crises? • Are privacy rules still followed? • Are they “bent” in the name of urgency? • Practice scenarios over and over (Consistent)

  14. Questions? • Les Seagraves • les.seagraves@corp.earthlink.net

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