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.

 

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
Tags: , ,

« »

No Responses

Comments are closed.


« »

Subscribe to our mailing list

Please fill out the form below.

Required

Want to find out more?

Simply go to the contact page, fill out the form, and someone from Privacy Ref will be in touch with you. You can also send an email to info@privacyref.com or call (888) 470-1528.

News

April 16, 2018

IAPP Training Classes
Privacy Ref is proud to announce that we are an official training partner of the IAPP. You now have the opportunity to learn from one of our knowledgeable privacy professionals using the most respected training content in the industry. The robust interactive training offered, aids in the understanding of critical privacy concepts. The contents of the courses are integral to obtaining your privacy certifications and to educate your new team. Learn more here.

Latest Blog Posts

July 9, 2018

Don’t Forget Basic Communication
Most of us have been wrapped up in GDPR preparations for several months. While there are many organizations "not quite there yet", many others have made great strides towards compliance. As we continue to do assessments for clients, both GDPR and General Privacy,  I have been surprised at the frequency of the gap between a privacy official describing their organization's data subjects, information collected, and business processes  with the reality of what is happening. Continue reading this post...

California – The Next GDPR?
Starting January 1, 2020, if you are a for-profit company doing business in California, you may have new data privacy compliance obligations. Specifically, California just enacted the California Consumer Privacy Act of 2018 (the country’s strictest data privacy law to date), placing new privacy mandates on certain businesses with respect to the personal information of consumers (defined as natural persons who are California residents). Many aspects of the new law smack of EU-GDPR influences, such as a new and improved (in other words, broader) definition of personal information and the inclusion of guaranteed consumer rights with respect to such personal information. If your business is already in compliance with the EU’s GDPR, the California law will be nothing new to you. For other businesses, however, you have 18 months to get with the program. Continue reading this post...

Other Recent Posts

PRIVACY REF