Global Business? Find Privacy Allies Throughout the Company
By Angelique Carson, CIPP/US
Finding the C-level executive who cares most is the first step in convincing the people at the top that privacy is important. With a CEO who is most likely juggling priorities constantly, it’s important to put privacy in context and bring home how a good—or bad—privacy program is going to affect the overall business. And sometimes, that requires help.
That was the opening message from Intel’ Chief Privacy and Security Counsel Ruby Zefo, CIPP/US, CIPM, during the “Secrets to Success: Accountability in Global Organizations” session at the IAPP’s Privacy Academy in Seattle, WA.
“A lot of privacy pros are ‘me, me, me,’” Zefo said. “But your CEO has a lot on his mind, so you need to put it in context. You have to have a big hook to draw in these people in order to get the tone from the top.”
At Intel, privacy is housed within the company’s code of conduct itself, the “Bible for all other compliance at Intel,” Zefo said. “It’s not like privacy takes up more than its fair share, but it’s in there, and it sets a principle from where everything else flows.”
Zefo said she provided background for Intel’s executive staff by presenting an environmental analysis of the status quo in order to “bring home the point” on how privacy issues could affect Intel’s business. It’s important to impress upon executives that privacy does not equal security, Zefo said, adding that sometimes “people who grew up making things secure don’t necessarily know the difference.”
Infusing privacy accountability across the business means creating advocates across the company and giving them as many tools for their toolkits as possible, Zefo said. And the best way to do that is to create easily understood, modularized training so that those people can then become “issue spotters” and remediate risk.
“We have advocates on antitrust and fairness across the company, and I’m trying to create little pieces of advocacy all over the world,” Zefo said.
To help in that effort, Intel has created a five-minute video, which includes cartoons for ease-of-viewing and entertainment value, indicating how various principles apply to an employee’s specific job.
“If you’re the health intake professional, what should you do? It’s really explained to the person sitting there, and it’s fast, easy and particular,” Zefo said, adding that Intel does a lot of trainings that incorporate situational learning. That’s because retention rates aren’t all that impressive when it comes to annual testing.
Jennifer Garone, CIPP/US, CIPP/IT, an IT manager at Microsoft who sat on the panel with her colleague, Marisa Rogers, CIPP/US, a data privacy manager at Microsoft, said the separation between security and privacy at Microsoft is “softening” a result of the realization that security enables privacy.
Rogers described Microsoft’s privacy program as using the “hub and spoke” model, which incorporates privacy mangers, leads and champions within organizations across the company, in that hierarchal order, the hub being Trustworthy Computing—acting sort of as the federal government, in this case—responsible for training, reporting and communications, and the spokes—engineering, sales and marketing, IT, services, etc.—being responsible for implementation and compliance with policies, standards and procedures.
Garone said Microsoft has found it very useful to build an incident and inquiry management tool, a dynamic database accessible only to classified individuals, which allows for incident reporting that then is streamlined to the correct privacy manager who handles it, reports on its progress, remediates the incident and documents the final result. She suggests organizations use similar tools rather than trying to report via e-mail.
“Then you can get the metrics, and it gives it visibility,” she said. “I think it’s definitely a model that people should take.”
Microsoft also employs a metrics scorecard. The color-coded scorecard—scored categories are marked in red, yellow and green—allows for Microsoft subsidiaries around the world to self-assess their status in each category relative to the corporate expectations.
“It helps them to understand where they stand against others in having a good privacy program so they can drive for improvements,” Garone said. “It’s helpful because it’s a quick snapshot.”
“Privacy scorecards are really important,” Zefo added. “Having the guts to say you’re ‘in the red’ is important.”
In the end, a good sell for obtaining resources in order to get the job done is to bring it back to the bottom line. Privacy should be pitched as a business enabler.
“Bring home the point that people won’t want the products if they don’t respect privacy rights,” Zefo said. “‘You won’t sell the products is a much easier way to sell it than ‘We aren’t going to be in compliance.’”
Zefo left attendees with three final messages: “Measure, measure, measure; leverage like-minded roles, and have a privacy elevator pitch.”
Because you never know when you might find yourself in an elevator with an executive who might just be your next best privacy advocate.
Read More by Angelique Carson:
This Week in Breach Roundup
Baker: The Grandfather of Privacy Was A Fogey
Changing Tactics: The Rise of the Privacy Advocates
How Should Your Firm Respond to the NSA Fallout?