How to Train Employees on Privacy Best Practices.
The vitality of a robust Privacy Program cannot be understated as compliance centric approaches lack effectiveness. In the U.S for example, building privacy solutions specifically to comply with state privacy laws can be futile as the landscape is constantly evolving. In 2024 itself we saw five more state laws being introduced and three state laws going into effect in July. While the laws may be similar, there are a number of subtle nuances and differences that cannot be ignored. To survive in today’s regulatory landscape and to thrive in the long run, privacy must become the default setting.
Implementing a strong privacy program and incorporating privacy best practices within an organization is not the sole responsibility of the Privacy Team. It requires changes to be made to every stratum of the company. This means that coordination and communication are key. Every employee within the company needs to understand the importance and effectiveness of privacy best practices and how they benefit the company overall. Let’s look at some key steps to consider while training employees on Privacy best practices.
While training employees on privacy best practices, it is first important to place employees into different buckets categories on their tasks and functions. This is done because based on the roles people fulfil, the training and information given to them will differ. For example, training given to engineering teams will differ from training given to other teams with access to Personal Information. For engineering teams, it is important that they understand the privacy standards and controls required for their products. For example, integrating SDKs that are privacy compliant, integrating with third parties for cookie compliance, setting up the IAB Global Privacy Platform (GPP) are some of the many strategies that support privacy best practices which engineers will have to be taught about when developing and working on their products. Here, it is absolutely crucial that the privacy requirements are considered when writing user stories and epics. Whereas for other teams, Privacy training will include communicating the importance of user privacy, ensuring different teams collect only necessary data from users/employees etc., promoting visibility and transparency of data privacy practices and reinforcing strong data security measures.
What should the training cover?
Depending on the team the training is conducted for, the content may vary slightly. Training for engineering teams might require more practical and technical content. It should also include important requirements specified by regulations so that they can understand the context around the privacy requirements. Overall, training should cover basics, such as what is data privacy, what is Personal Information (PI), what is sensitive information, what is the difference between the two, what is a data breach and how data breaches occur. It also should communicate the organization’s own privacy policies and procedures.
Next the training should outline actionable steps for employees to follow. For example, data minimization can be broken down to collecting only the amount of data that is legally allowed, collecting data only to the extent required for the purposes for which they are collected, applying data deletion schedules on data depending on their purpose, etc.
Finally, the training will need to cover the different changes that employees will have to make so that they contribute to the larger changes in organization culture. This can include cross collaboration across different functions and departments of the company to ensure coordination of efforts, for example, different teams may have to come together to outline their uses and needs for user data so that data will be collected for those purposes only. Or different teams like marketing and HR may have to come together to understand data retention requirements, i.e., for how long each department would need to retain Personal Information. Changes in work culture would also include heightened data security measures that each individual will have to follow to ensure that the data they handle, maintain and have access to is safeguarded. Furthermore, only the right personnel should have access to the data at the right time.
When and how often should the training occur?
Privacy trainings need to happen in the early stages of implementing the program so that all employees are aware of the new requirements from the get-go. Following that privacy trainings should be provided before an individual obtains access to confidential or personal information. Or when new members are inducted to the company or to new specific teams and departments depending on the privacy requirements of those teams/departments. Trainings should also be conducted when there are changes in company policies and procedures, changes in regulations and changes and evolutions in technology. Trainings may also need to be conducted when there are changes in organization infrastructure, for example during mergers, acquisitions, or when employing or collaborating with third parties.
At the end of the day, privacy trainings are not a one-time task. These trainings have to be updated and conducted on a regular basis. With the constant evolutions in regulations and technology, we cannot expect training and information to remain relevant for a long period of time. Furthermore, we have to understand that humans are prone to errors and some information and certain changes may take a while to set in. While regular training may seem like a tedious activity, there is no better catalyst for change within an organization than the members of the organization itself. The success of the privacy program can be measured by the success of each individuals’ efforts towards implementing the best practices in their own tasks.
