What, Why, and Who: The Essential Questions
By Patrick Midden, CIPP, CHPC, J.D.
Some companies see complying with privacy requirements as a roadblock; a hindrance; a problem to avoid. They think privacy regulations are too onerous, or too complex, or do not apply to them. These companies sometimes take a “stick your head in the sand” approach to privacy and hope everything just works out. But successful companies are learning that a privacy program doesn’t have to be a burden; implemented effectively, a privacy program not only reduces company risk, but it can help drive process improvements.
Most privacy regulations and frameworks provide ample room for interpretation as to how to implement an effective program. Most of them, though, require at least asking some basic questions, including:
- Why are you collecting and using personal information?
- Do you need all of it?
- Who should have access to it?
An effective privacy program will answer these questions and more. Answering these questions can help uncover inefficient processes. An effective program might uncover inefficiencies, such as:
- Employees accessing sensitive information that is not needed to do their jobs.
- Employees redundantly storing information in multiple systems without appropriate controls.
- Employees manually updating information across multiple systems.
But how can a privacy program help improve these processes? Collecting less data means your employees will spend less time processing it. Giving employees access to the right data at the right time means they will spend less time looking for it. Storing less data requires less disk space, less archive space, and less processing time.
In addition, many employees do not take the time to understand what they are doing; instead, they just do what they were told to do by the last person to do their job. New requirements are layered on top of the old process without analysis, making the process more complicated and difficult to follow. Reviewing your procedures for privacy risks will help these employees understand what information is important, and what information is not. This review can lead to streamlining processes, cutting out steps that are no longer relevant, and optimizing the remaining steps.
Some examples of how a privacy program review could help include:
- An employee at Company A makes a daily back-up copy of sensitive data outside of the official back- up processes. No employee at Company A ever looks at these old files, nor needs them. This process is inefficient because Company A is paying the employee to spend time performing a function that is already controlled through a central process. The process is also inefficient because the employee is wasting company resources by redundantly storing data.
- Company B always includes a social security number on each customer record, even ancillary systems in which social security numbers are not relevant. Company B encrypts records containing a social security number. By removing social security numbers—and other sensitive data—from ancillary systems, such as customer satisfaction tracking systems, Company B can stop encrypting these databases, saving Company B time and money.
- Company C uses an inventory system that lists every patient who is waiting for medical supplies. Employees responsible for ordering these supplies can only determine what to order by logging into the primary care system and retrieving the appropriate patient records. By creating a daily report that lists all devices that need to be ordered, but not listing any patient information, the inventory staff can do their jobs more quickly, without accessing any patient information.
These are just some examples illustrating how integrating privacy program objectives into daily procedures can reduce the amount you need to spend on (1) data storage, (2) data processing, and (3) security. A thorough privacy review can even reduce the amount of time your employees spend performing their everyday tasks by helping streamline processes.
If you are interested in learning more please reach out to us at SDS.