Privacy Ref Blog

Valuable functionality can cause a privacy breach

Last Friday it was revealed that reporters from Bloomberg News could retrieve information from the profiles of subscribers to Bloomberg’s data terminals as well as the subscribers’ system usage (NYT article here). While I agree with the characterization of this incident as a “mistake”, wasn’t this really a violation of basic privacy principles?

The ability to see user profiles and their system usage is a valuable feature that can be used by administrators or help desk staff. However, this is the type of functionality that should be restricted to those who have a need to know.

No matter which data privacy framework you prefer, there is a tenet that states that personal information should be used for the purpose specified at the time of collection (or in the privacy notice). A corollary to this would be that any additional use would require an additional disclosure to the data subject. In the Bloomberg case these maxims were just not followed. Implementing a role-based authorization scheme would have allowed the retention of the functionality while protecting subscriber privacy.

One needs to ask if, at the time of development, privacy requirements were included in the specifications for the application. If not, it was clearly a mistake. Alternatively, it would not be unusual for the capabilities of the application to grow over time resulting in the potential for undisclosed access. If so, one needs to ask if privacy requirements were considered as new functionality was developed. In either situation the principles of Privacy by Design could have been leveraged to avoid the privacy breach.

It is a fair assumption that the functionality was not a secret within the Bloomberg News organization. An additional concern then is that either no one thought enough of the potential privacy implications to report the privacy risk or no one recognized that a privacy risk existed. This underscores the need for a clear internal privacy policy with supporting training and awareness programs.

By considering privacy requirements up front and establishing an effective privacy training and awareness program, the brand damage, public relations, and relate operational costs of addressing situations such as this can be avoided.

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    By: Bob Siegel

    Bob Siegel, the founder and President of Privacy Ref, Inc., has extensive professional experience in the development and improvement of privacy policies and procedures, the definition of performance metrics to evaluate privacy maturity, and the evaluation of compliance. He utilizes a combination of alignment, adaptability, and accountability strategies to guide organizations in achieving their privacy goals.

    He is a Fellow of Information Privacy (FIP) and a Certified Information Privacy Professional, awarded from the International Association of Privacy Professionals, with concentrations in U.S. private-sector law (CIPP/US), US public sector law (CIPP/G), European law (CIPP/E), and Canadian law (CIPP/C). He is also a Certified Information Privacy Manager (CIPM) and Privacy Technologist (CIPT).

    Siegel is a member of the IAPP faculty, has served on the Certification Advisory Board for the CIPM program the Publications Advisory Board.

    Siegel also writes the blog “Operational Privacy” on CSOonline.com

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    Preparing your customer-facing staff
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Privacy Ref provides consulting and assessment services to build and improve organizational privacy programs. For more information call Privacy Ref at (888) 470-1528 or email us at info@privacyref.com

Posted on May 12, 2013 by Bob Siegel
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