Practical strategies for creating a privacy culture in your organization
By Kim Bustin, CA, CIPP/C
Some of the most common privacy breaches happen when personal information is stolen, lost or mistakenly disclosed. Most of these breaches could have been avoided if the individual involved simply thought about privacy before acting. What’s needed is an environment, or “culture,” where protecting clients’ privacy is top of mind for every employee whenever that person handles personal information—a privacy culture.
Culture can be defined as “an integrated pattern of human knowledge, belief and behavior….that characterizes an organization…” It follows, then, that individuals responsible for privacy should:
- Closely align the importance of privacy with the organization’s values system, and
- Implement strategies to convert the knowledge about privacy and belief in its importance into repeated practices that will shape the culture over time.
This article will explore some practical strategies for creating the essential elements of a “privacy culture.”
Strategy 1: Get the basics right
An important first step in creating the desired privacy culture is to assess the current state of the organization’s privacy program including privacy policies, breach response protocols and training. Consider whether there is a general awareness and agreement among management of privacy risk areas in the organization or whether there is a strong sense that “we don’t know what we don’t know.” If the latter is the case, completing a privacy gap analysis to identify personal information holdings and analyze how personal information is protected and managed may be a good first step. A privacy gap analysis can provide objective data about the organization's current level of compliance, build awareness among senior decision-makers of key privacy issues and risks and send a strong signal to employees that protecting personal information is a serious matter.
Strategy 2: Align the organization’s privacy program with its strategy and values
Help top management and the board understand the connection between a strong privacy culture and the organization’s ability to deliver its business objectives. Educate senior leaders on the potential impact of privacy risks by providing examples of breaches in similar organizations and how they could have been avoided, painting the picture of what might occur if risks are not addressed. Use real examples to demonstrate the value of privacy to the organization’s brand, its reputation and, if possible, its bottom line. Time invested here is time well spent, as it is extremely difficult to shape a culture without the active support of top management.
Many leading organizations build responsibility for protecting the privacy of employee and customer information directly into their codes of conduct. Top companies require employees to formally review and sign off on their understanding of the code every year. This is an excellent way for senior management to convey the message that privacy is not only important, but it’s “the way we do things around here.” For this strategy to work well, managers must model the behaviors demanded by the code, and instances of employee non-compliance must be dealt with swiftly and consistently.
Strategy 3: Integrate the privacy program within existing business processes
The next step is to define the critical business functions within the organization with which you will align and imbed your privacy program. Some of the key integration points you may want to consider are listed here.
Incorporate privacy training within the organization’s orientation program for new employees, and require new employees to complete privacy training before being granted access to systems containing personal information. Make annual privacy refresher training a standing component of the company’s master training plan maintained by HR to ensure that privacy training continues to be funded.
New business development /capital project approvals
In many organizations, new initiatives are selected and capital is allocated using a “gating process,” where concepts are reviewed and proceed through a series of increasingly rigorous assessment phases—or “gates”—until they are ultimately either rejected or approved, often by a cross-functional team of senior decision-makers. Work to make privacy risk management tools part of the documentation required at each “gate.” A standard set of questions about the personal information to be collected and used in the project can identify privacy issues at the project’s conceptual stage. Similar but increasingly more robust privacy risk assessment tools or checklists can be built into the documentation required at subsequent stages of analysis, including business case development, and can be used to identify whether a Privacy Impact Assessment (PIA) will be required. PIAs typically begin after the business case has been approved, early in the new system’s design phase.
The project management office
Work with the project management office to demonstrate the value of “privacy by design,” using real examples from your organization, if applicable. Point to instances where a major information system’s design had to be reworked to accommodate privacy requirements identified after the development process was completed. Demonstrate the benefits of proactively planning for privacy as they relate to controlling the project’s budget and schedule on which project managers are evaluated. Solicit project managers’ support in reinforcing with business owners the need to complete a Privacy Impact Assessment or similar review early in the design phase for projects involving personal information, and imbed formal requirements for privacy risk assessments within project management deliverables.
Procurement and contract management
Work with the tendering, purchasing and contract-management functions in the organization to ensure that privacy requirements are appropriately incorporated within all public tenders, system or vendor requirements documents and selection criteria for major purchases involving personal information. These groups of professionals are generally aware of all plans for major new purchases and can work in partnership with the chief privacy officer to ensure that privacy is part of all purchasing processes and decisions. Help to streamline procurement processes by supplying staff with a standard list of minimum privacy requirements in advance, creating privacy-based criteria for vendor selection and developing standard contract clauses.
Organizations with mature enterprise risk-management programs regularly report changes in the company’s risk profile, including the status of risk-mitigation strategies, to senior management and the board of directors. Ensuring that privacy and other information risks are represented on the corporate risk report can prompt important discussions among senior leaders about the organization’s tolerance for privacy risk and garner support and resources for your privacy program as a corporate risk-mitigation strategy.
Many organizations have existing incident management or critical issues management processes that are already familiar to employees. Tap into these processes when creating your privacy breach protocols.
Strengthen accountability for results and reinforce the progress you are making in creating the desired privacy culture by defining critical measures of success. Regularly report progress using existing corporate performance-measurement approaches such as the balanced scorecard.
After the fundamentals of a strong privacy program and top management support are in place, privacy leaders must decide which strategies should be pursued in order to firmly imbed and integrate the desired privacy practices within the organization’s business processes. This article has provided some strategies that may be useful to privacy leaders in creating the integrated set of knowledge, beliefs and behaviors that will define their organization’s privacy culture.
Kim Bustin, CA, CIPP/C, is president of Bustin Consulting Limited. She is also a member of the IAPP Publications Advisory Board. She can be reached at email@example.com.