“Top Ten” list of initiatives that any business concerned about privacy should take NOW

(from “The E-Privacy Imperative--Protect Your Customers’ Internet Privacy and Ensure Your Company’s Survival in the Electronic Age,” by Mark S. Merkow and James Breithaupt (AMACOM 2002)

1. Review your current privacy policies. Are they sufficient to address the concerns of your customers? If not, determine if you have the resources in-house to create your policies; if not, consider looking for outside help.

2. Educate your employees about the importance of privacy matters both to the customer and the company.

3. Understand current and pending state and federal privacy legislation that might affect your operation. Vigilance is the byword here.

4. Consider hiring a CPO if your organization is large enough and can afford what should be a highly visible management position.

5. Review the security of your systems. Privacy is not just about policy and legislation. It also means protecting your data from both internal and external threats.

6. “Mystery shop” on your own site by planting data about fictitious customers with mailing addresses and e-mail IDs that you can monitor to see if information leakage is occurring.

7. Keep up with international laws that may affect your business, including the Safe Harbor provisions and OECD (Organization for Economic Cooperation and Development) directives for information privacy and security.

8. Subscribe to consumer protection services (like BBBOnline) and join organizations that focus on consumer issues related to privacy.

9. Participate in seal programs to help assure your customers that you’re serious about their privacy concerns.

10. Because technology won’t stand still, revisit each of these steps at least annually to maintain a strong privacy posture.

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