Privacy Ref Blog

Radio Shack’s Privacy Notice Oversight

rshacklogoGrowing up I spent a good amount of time at Radio Shack. I liked to “play” with electronics just to understand how things worked. It always bothered me that they asked for my zip code for every transaction, but they still got my money. That may be in part why I became a privacy professional.

I continued to visit the chain in recent years, mostly for batteries and replacement parts. How was I to know that, in spite of their privacy notice, Radio Shack would eventually try to sell my personal information during their bankruptcy.

Radio Shack’s online privacy notice

Within their on-line privacy notice, which only applies to RadioShack.com, there is a section discussing information sharing and disclosure.Almost all privacy notices have a similar section describing when and why personal information may be disclosed.  (Note: I was too late to visit the local store to see the posted version.)

Radio Shack’s privacy notice states in the sharing and disclosure section:

Agents, employees and contractors of RadioShack who have access to personally identifiable information are required to protect this information in a manner that is consistent with this Privacy Policy and the high standards of the corporation.

As a privacy professional I feel pretty good about doing business with a company with a notice and, hopefully, an associated internal policy that severely limits the sharing of my personal information. I leave to Attorneys General and regulators to decide if the selling of customer personal information in this case is actionable (but I would suggest it may be).

What is the privacy notice missing

We can never predict what will happen during the transition of a company during bankruptcy or acquisition. Customer lists and the associated personal information is an asset. There is a good chance that during a transition a company will want to derive some value from this data.

Adding a single bullet point to the privacy notice could easily address personal information sales during a transition. For example the following statement comes from the Staples.com privacy notice:

The privacy team at a company needs to think ahead and leave the company options for the processing of personal information that management running the day-to-day business operations may not consider. Addressing the transfer of personal information if, and when, a transition occurs is just one of these situations.

 

  • author's avatar

    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

  • author's avatar

  • author's avatar

    Preparing your customer-facing staff
    Automation for Privacy
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    See all this author’s posts

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 March 26, 2015 by Bob Siegel
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