Developing talent • Growing ventures • Opening markets Visit us at marsdd.com Data Privacy Day: The Startup’s Guide to Privacy January 28 th , 2016 JANUARY 2016
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Data Privacy Day: The Start-‐up’s Guide to Privacy January 28th, 2016
J A N U A R Y 2 0 1 6
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1. Why invest in privacy? 2. What do I need to do?
– Understand the LegislaQve Landscape – Develop a Privacy Management Program
• AccountabiliQes • Risk Management
• Privacy OperaQons
3. Where can I get more informaQon?
Agenda
September 2014
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• Know what privacy laws apply to you and your customers: – Business Models:
• Business to Business • Business to Consumer
– JurisdicQons: • Ontario • Canada • U.S. • World
LegislaQve Landscape
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Privacy Program
Governance and
Accountability
Privacy Operations
Privacy Risk Management
Develop a Privacy Management Program
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Privacy Risk Management
• Privacy Impact Assessment – IdenQfy Privacy Gaps – MiQgate Privacy Risks (Admin. & Tech.)
– Consists of: • Authority • Data Flow (CollecQon, Use and Disclosure)
• Assessment
• MarkeQng Tool
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• Appoint a privacy officer • Create Privacy Policies • Confiden6ality Agreements • Privacy and Security Awareness Training • Create a culture of privacy
Governance and Accountability
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Appoint a Privacy Officer
• PosiQon will depend on size and complexity of organizaQon – Large organizaQon – dedicated privacy
person – Small organizaQon – assigned to someone
with other responsibiliQes
• Must have the authority and resources needed to deal with privacy issues
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Privacy Policies
• Overarching privacy policy • Privacy statement suitable for the
public and published in a brochure or on website
• OperaQng policies addressing major privacy issues such as consent, disclosure, client access
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Confiden6ality Agreement
• Make everyone who handles personal informaQon sign a confidenQality agreement.
• Ensure that they understand their obligaQon to keep personal informaQon confidenQal and the consequences of breaching customer privacy.
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Privacy and Security Awareness Training
• Security and Privacy Awareness training for all staff who have access to personal informaQon
• Specialty training for privacy officers, app developers
• Consider different approaches: – Classroom style
– Videos – Computer-‐based training
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Culture of Privacy
• Make privacy a core value • Privacy is good for business • Promote secure behaviors • Senior Management must lead by
example
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Privacy OperaQons
• Incident/Breach Management • Consent Management
• Individual Access & CorrecQon • Complaints & Inquiries
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Be ready for a Privacy Breach
• Privacy Incident: Unauthorized or illegal access to, or use, collecQon, disclosure or disposal of personal or personal health informaQon. A privacy incident results from a privacy breach.
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Consent Management
• Obtain Consent • Withdrawing Consent
• Overriding a Consent DirecQve • ReinstaQng Consent
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www.privacyhorizon.wikispaces.com
Privacy and Security Links
Privacy and Security Resources
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THANK YOU!
B E C A U S E T H E F U T U R E M A T T E R S
I NNOVAT ION