A successful privacy awareness program includes ongoing activities to keep privacy “top of mind” for the members of an organization. It supplements a privacy training program that conveys information in a formal learning environment. For an awareness program to meet its goals, a training program must prove the foundation for your privacy program.
Information to include in a privacy training program
Privacy training has the challenge of establishing the basic concepts of privacy that relate to all your stakeholders. The training must also convey how trainees must behave to meet the organizational requirements for protecting personal information. To successfully and efficiently teach the basics of privacy while maintaining the interest of the attendees, it is useful to break the audience into groups with common responsibilities for utilizing and protecting personal information.
Consider a multinational corporation. Those people with global responsibilities, such as a centralized information technology or human resources function, should be identified to receive privacy basics with a global perspective. However, members of divisions that operate in a single jurisdiction may receive privacy background information that is relevant to them with acknowledgement of privacy requirements in other jurisdictions. A US-based division, for example, would have training that focuses on the nature of privacy in the US with some limited commentary about European and other jurisdictional requirements from around the world.
Information on organizational expectations for protecting personal information, however, should be consistent for all parties being trained.
When to give privacy training
Privacy training should be provided when someone begins working for an organization and then annually thereafter. A central resource, such as HR, should be used to track who has been trained and when.
One strategy that some organizations apply to insure that privacy training is completed in a timely manner is to deny access to computer systems for those staff members who are not up to date on their privacy training. This not only raises the priority of the training for the staff, but creates the time for them to take the training if they are late and reduces the risk of their inadvertently violating organizational privacy policy.
Training should be provided to everyone processing or accessing personal information on behalf of an organization. This includes not only direct employees at any level, but contractors and temporary workers as well. Often, the training of these last two groups is left to the manager to which they will report essentially insuring that the training is unlikely to occur.
How to give privacy training
Formal privacy training can be provided any of several ways. Classroom training provides the best way to convey this information; recent events may be used as examples during the training plus questions posed by the attendees may be answered immediately. Also, the training may be customized to address local cultural requirements.
A second approach is to give training through a webinar. Here again, recent events can be used as examples and questions may be answered. That local touch, however, is missing.
A third approach is to use computer-based training, or CBT. Utilizing this approach ensures uniform training is to all participants. It also allows participants to take the training at a time when their schedule and workload permits. CBT also allows for a quiz to be given to the participants once the training is completed to make sure their understanding of the information presented. However, CBT cannot take advantage of using recent events as examples, nor offer an easy way to have questions addressed.
Executive participation, a key to training success
Some of the most successful privacy training I have seen included endorsement by a senior executive at the start of a class. Optimally an executive would give an introduction with personal insight prior to the start of a class or a webinar. Alternatively, a video of an executive providing this same perspective may be used.
Also, the impact of an executive attending the same training as everyone else in an organization should not be overlooked. At a recent training series I conducted, members of the “C” suite were in attendance. In addition to re-enforcing how important privacy is to an organization simply by their participation, the executive re-enforced the messages included in the training during the breaks when speaking with the other staff members.