Best Practices in Global Data Privacy
May 26, 2021, 09:00 AM by BBB National Programs Global Privacy Division
Privacy has become a very public matter. Business news sites, TV business networks, and the pages of major newspapers are full of stories on the topic of – and the controversies related to – data privacy. The issue of properly managing personal data is not only big in the U.S.; it is increasingly important around the world.
If you are striving to build a business with a global reach, you must take cross-border data privacy seriously. Today’s economy requires using systems that process data from around the world, even if you do not yet sell or operate outside the country where you are headquartered. And using data, especially personal data, in global commerce means you must comply with a growing labyrinth of privacy-related regulations.
Forward-thinking business leaders, like those who are working with us at BBB National Programs, must commit to embracing established standards for privacy and data security. To do this right, you must have insight, documentation, and transparency.
Every business relationship with personal data is unique, so creating an inventory of your collection and use of personal data is always the first step. Ask yourself, what types of personal information does our company or non-profit organization process? Once you have that list, you should ask a series of questions about each data type, such as:
- Is it sensitive information?
- Where does it come from?
- At the time it’s collected, what kinds of permissions or limitations are set out about how it can be used?
With the answers to these questions in hand, and following straightforward data best practices, you can customize and document your processes and procedures for handling the personal data you collect. Crafting operational practices that fit your data inventory requires consideration of how all of your data insights translate into practical action steps for handling that data.
Strong privacy practices enhance business relationships with customers and other stakeholders. Enhancing relationships includes making sure that their expectations match reality when it comes to how personal data will be processed. With your policies and procedures in hand, it is a natural and straightforward step to craft informative notices of your privacy practices.
Certifying Your Practices
These internal privacy practices only get you part of the way. Independent indicators are needed to verify that your practices are, in fact, in accordance with recognized standards.
Third-party privacy certifications do just that, while at the same time helping your privacy strategy remain interoperable with a variety of legal regimes. Similarly, independent dispute resolution for customers with privacy complaints provides a second layer of trust, while providing consumers with a responsive redress mechanism that sets your customer service apart. This type of mechanism is also mandated by international frameworks like APEC and Privacy Shield.
Your business reputation for privacy also depends on the practices of your vendors and partners. Once you know who touches your data and where that data is stored, it is up to you to conduct ongoing due diligence to make sure your partners treat it consistent with your standards, practices, and public statements.
Thankfully, you don’t have to reinvent the wheel or dedicate internal resources to vet your contractors.
- Ask your vendors to secure trustworthy third-party certifications about their privacy and security practices. Look for services and mechanisms like Cross-Border Privacy Rules (CBPR) or Privacy Recognition for Processors (PRP).
- Next, use standardized contractual requirements to hold your business partners to the same standards and trusted best practices you expect of yourself.
Find the Right Method of Accountability
Getting global privacy operations right means embracing a “Show and Tell” approach. Your voluntary commitment to independent mechanisms of accountability, such as certifications, assessments, or independent dispute resolution can provide that trusted verification.
Even in an environment where global privacy regulations are actively shifting, maintaining a robust privacy program with independent indicators will go a long way toward minimizing the scrutiny of consumers and government agencies.
Our role at BBB National Programs as a third-party provider of privacy certifications, assessments, and independent dispute resolution is to help companies confidently demonstrate that their privacy practices are built upon the principles that form the building blocks for global privacy standards.
We can help make privacy achievable and accountable for businesses of all sizes. Reach out to GlobalPrivacy@bbbnp.org to get started.