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You may be interested in how Wells Fargo has been handling the fallout from their recent scandal.  The summary of the incident is that sales personnel at Wells Fargo were so pressured to meet numbers that they created fake accounts using real consumer information. The practice was rampant at the company.  After being fined just short of $200 million by the Consumer Financial Protection Bureau, Wells Fargo’s executive board was faced with new challenges, specifically holding onto their positions on the board.

The concept here is that the board of directors should have known about the sales activity and quashed it early.  Many called for the board of directors to get voted out, but surprisingly all of them kept their positions on the board.  There are many take-aways from this story, but from a privacy perspective, it is all about responsibility.  As President Truman said, “The buck stops here.”

Accountability is part of responsibility

Many laws and regulations, such as HIPAA, have requirements for a point of contact to handle privacy matters. An organization, regardless of industry or requirements, should have a privacy person or team..  This team is accountable for privacy, for pointing out possible conflicts or issues, and keep your business compliant and healthy.  It is important though that this team has the ability to perform core functions, such as assessing against compliance or running vulnerability tests.

Any organization with a privacy program, or still in the process of developing a program, knows that having a privacy champion or champions is core to their program.  Either a chief privacy officer or a privacy team should be in place to assess and review how your organization complies with laws, regulations, and other requirements.  This is the individual or team that should see that something is going wrong, such as misuse of consumer info, and report it immediately.  In the case of Wells Fargo, they could have stopped misuse early. In the event of ignored or allowed misuse, they would be accountable for this.  It is certain that there is a privacy team at Wells Fargo, but if this wasn’t ignored, but simply never found, it then shows the importance of regular monitoring of accessed information.

After all is said and done, Wells Fargo was fined by the CFPB and faced a potential shake up of their board.  This is to say nothing of any potential lawsuits from consumers.  Monitoring information, and having a team responsible for the way in which data is handled and secured can keep a business moving in the right direction.

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

Posted on May 10, 2017 by Ben Siegel

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