Punit Bhatia is an advisor with FIT4PRIVACY who helps leaders create and implement their privacy compliance strategies.
As data-collection technologies have expanded, consumers have become more vocal about their concerns regarding their privacy and how their data is being used. Respect of privacy creates trust, and one of the great ways businesses can affect the trust of consumers is through their actions in the context of compliance with privacy laws. This is why ensuring you are compliant with privacy laws such as EU GDPR and CCPA can be a key component to ensuring your company’s success.
It has been five years since EU GDPR came into effect, but many companies still struggle to start their privacy compliance journey in time. It can be a serious blow to have your product or service ready for release, only to discover that those compliance factors are non-negotiable and take time to complete. To avoid these last-minute hassles and the costly delays they can bring, here are my five tips for starting your compliance journey at the right time and in the right way.
1. Begin with the end in mind.
When you are preparing to evangelize a product or service, it is essential to know who will consume it. Ask yourself which markets your product will be available in, and plan ahead for any compliance regulations you will need to meet before the product launches. For example, if the consumers will be residents of the EU, you will need to be compliant with EU GDPR.
2. Start early.
The biggest mistake some companies make is thinking about privacy compliance as mere paperwork that can be done at the last minute. However, there is much more to the process than filling out legal documents or publishing some notices on your website. I would recommend starting your privacy compliance process at least 12 to 18 months in advance of the product’s launch.
3. Assign responsibility.
We all know that things are more likely to get done when ownership is defined. The same goes with privacy compliance, so assign this responsibility to a senior executive. I would recommend giving this assignment to your Chief Operating Officer (COO), Chief Information Officer (CIO) or Chief Information Security Officer (CISO). Your legal team should also be included, but in my experience, involving an executive on the business, technology and/or operations side of your organization is important, as most compliance actions will relate to these areas.
4. Dedicate resources.
When you assign responsibility, it is also essential to allocate the necessary resources for completing the process. By resources, I mean both budget and manpower. You can always hire dedicated staff for this, but I recommend starting with an external consultant, as they should have the expertise necessary to fast-track your journey and help ensure that you start the process right. They may even help you learn what you need to know in order to hire the right staff for future compliance projects.
5. Think global.
This is key. Most companies think of complying with EU GDPR, CCPA, or CPRA specifically, but privacy is becoming a global issue. If you take the approach of complying with each law individually, you will likely end up running initiatives/projects every time a new law is passed. Instead, I recommend building a law-agnostic privacy compliance approach that incorporates the strictest laws (covering at least 80% of the situations you may encounter), then implementing any internal actions in line with that strategy. This way, most situations you may encounter will already be covered, saving you from having to initiate new compliance programs every time you roll out products into new regions.
Why invest in privacy compliance? Well, research suggests that consumers trust companies that structurally demonstrate transparency about what personal information they collect and how the privacy of that information is ensured. When you are creating a product or service to serve individuals, how can you succeed without winning their trust? Remember that trust, once broken, is very hard to earn back. So start right and start early with your privacy compliance journey.
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