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Tailored Privacy Training Curriculum

By Scott Crosby, President, Sysanova Ltd.

This is the third in a series of four articles on privacy training, and deals with the curriculum development for specific work groups. Previous articles dealt with Privacy Training Strategy and Privacy Training Needs Assessment.

It is at this stage that the training becomes really focused on the workgroup and their role in the overall operations of the company. While it is true to say that nearly everyone in an organization will require privacy training, there are some groups that will require it sooner rather than later, and some groups can be dealt with fairly quickly as they require merely an overview session. Other groups will require detailed training on the legal responsibilities, and on how the organization plans to fulfill these responsibilities, and capture the value in privacy as a differentiator from the competition.

Tailoring the curriculum to specific workgroups creates the opportunity to gain the most from a privacy management practice. Any company can create a privacy policy and publish it, send it out in mail outs or post it to the website. However, such actions are simply the icing on the cake. The real challenge is ensuring that the organization can develop detailed policies and practices, and even more, can live by them. It is highly risky to make a public policy statement and then be proven to be unable to follow through on the statement. Developing training curriculum specifically by workgroup will ensure that the organization has applied due diligence toward getting it. Having a thorough and valid policy statement goes a long way to defending against such complaints and avoiding them in the first place, and towards illustrating to your workforce and clients that the company considers its relationship with them important.

Most corporations of medium to large size have sectors dealing with specific tasks.  They might be divided into three basic groups. The Executive team, the Operational team and the Support team. Each group could then be sub-divided further. The Executive team might include an executive board, an audit function, public relations and legal advisors. The Operational team would have a sales team, service or product development team and delivery team, a regional infrastructure and marketing staff. The Support team would house the financial services, human resource team, information and technology management team, security, telecommunications and other support functions. Each one of these categories will require training with different focuses.

The Executive team

The curriculum for the Executive team needs to cover the basics from a high level. Starting with the laws themselves:

Executive Team Privacy Training Curriculum

Subject Components Details
Legal basis
  • PIPED
  • HIPPA
  • FCRA
  • Provincial laws
  • federal laws
PIPED:
  • Role of CPO
  • Role of Commissioner
  • Responsibilities of Customer Service Representatives
  • Code of Fair Information Practices
  • 10 Principles
  • Notification requirements
HIPPA
FCRA
Corporate Policy
  • Customer databases
  • Customer relations
  • Employee databases
  • Employee relations Privacy Policy
Statements in each policy regarding the 10 principles and how they are implemented for all types of personal information
Corporate Practices Personal Information collection, use, disclosure, retention practices Who collects personal information, what information it is, where it goes, information flow, what changes are taking place due to PIPED, access procedures, public relations component, security component, information management upgrading, notification and consent activities
Privacy as a societal value   History of privacy, current survey results, privacy infractions and public reaction,  other jurisdictional activity, OECD, EU, Safe Harbours, workplace surveillance etc

This table shows an example of a curriculum for the Executive Team. It’s components would be different for any other workgroup, for example, the public relations staff would need detail on messages for customers, information protection measures, limiting collection of personal information, how to file a request, how to file a complaint, what types of information are stored and where etc. Whereas Information Technology staff must be trained on minimizing collection, security requirements, use and disclosure components and data mining considerations. An orientation program for new staff would also have a different curriculum, one that more closely resembles the Executive Teams’ curriculum and offers a broad perspective content that contributes to meeting the goals of organizational cultural change, upgrading skills and awareness of the law and the customer relations dynamics imbedded in privacy management services.

At this stage of developing a privacy training plan, consideration needs to be given to delivery techniques, detailed schedules, hand out material, pre-reading, follow-up reading and references to websites. Once the training is delivered, measuring how it is meeting your original strategic goals is critical. This will be considered in the next article.