Choosing a privacy framework

Developing a privacy program for any organization is a daunting task. You need to be aware of your organization’s information requirements, be aware of the applicable laws and regulations, be culturally sensitive, be a strategist, be a teacher, be a leader, be a communicator, and much more....

How to help people understand your Privacy Policy

Privacy policies have become fairly standard items on company websites. There is much valuable information provided and we really want users of our website to understand what we have written. Since most people do not eagerly read every word of any article or document, it is key to allow them to e...

Cookies with consent, not milk

Back in August 2019 the Data Protection Commission examined about 40 of the best known organizations’ websites across different industries. The purpose was to gauge compliance with current regulations regarding cookies and tracking technologies. A small group of organizations fared rather well bu...

CPRA: New Definition of Consent

“Consent” is defined as any freely given, specific, informed and unambiguous indication of the consumer’s wishes he or she, or his or her legal guardian, by a person who has power of attorney or is acting as a conservator for the consumer, such as by a statement or by a clear af...

Privacy Laws are converging

After learning of the latest information on the pending Virginia Consumer Data Protection Act, one of my clients exclaimed “If every state comes up with their own rules, this is going to be a nightmare.” Yup, but in the long run, privacy laws are converging.

Your Staff (still) needs to be “privacy aware”

When it is all said and done, no matter what policies you put in place, no matter what procedures you define, no matter what documentation has been written to support your privacy program, it is worthless unless your organization’s staff knows that these items exist. Without the team being “priva...

Kick-starting a privacy program … revisited

It is not enough for a business to create a privacy notice and place it on its website; a business must define policies and practices, verify that their employees are following the practices and complying with policies, and confirm that third-party service providers are adequately protecting any ...

The Astounding Mishap of Parler

Many of us have become aware that the social media site Parler was essentially shut down after a number of service providers refused it further service. Without cloud services and hosting, the site simply lost the ability to function. Possibly less known, however, is that just before this happene...

Passwords for Shared Devices

My wife and I went shopping for furniture this weekend. After isolating for months, it was a pleasure to be outside and doing something seemingly “normal.” When we entered the furniture store, we were met by a salesperson with a tablet in hand. As we worked with her, I realized how ex...

Privacy and COVID

My wife and I have been very careful about “staying within our Bubble,” but it was bound to happen. Someone outside of our small group had encountered someone who tested positive and the “Bubble” began to burst. It made me consider privacy in this time of pandemic. How the bubble came in contact ...