Nuts & Bolts - Eye on Privacy: How to Grow Your Privacy Team in a Down Economy
It may not be in their job descriptions, but your marketing, sales and business development folks are important parts of the privacy team. This is especially so when it comes to the complexities of dealing with partners and clients.
Recently, I experienced a couple of separate instances that serve as informative examples to folks in the industry on how to manage the winding and often uncertain byways of client/partner relationships.
One of NextAction’s prospective partners, an online content publisher, wanted to derive incremental revenue from understanding the interests of site visitors. Because the partner had not worked with network advertising before, it did not have the necessary systems in place to comply with the notice and choice policy requirements for our (or anybody else’s) online ad recommendation product. This was raised very early in the discussions because it is an integral piece of our contracts, and we are blessed with smart business development folks.
Working with our business development team, we were able to show the partner a direct path to compliance, thus opening the door to a new way to monetize its content. This is good for the publisher, for us and for the site users who prefer not to participate. As I write this, the publisher is updating the notice and choice provisions of its privacy policies to include notice and choice about third-party cookies.
What, Me Worry?
Recently I was working with a very knowledgeable colleague at a large CPG company at the same time that the Interactive Advertising Bureau Lead Generation Committee—on which I sit—was fielding a survey of lead-generation security practices. When I asked my colleague to participate, she immediately thought this was a marketing technique in which her company did not participate. She was surprised to discover that her far-flung company was both active in the space and already adhering to many privacy and security best practices.
I viewed this for what it was: She had done a great job at educating her marketers on the high-level privacy goals for the company, and they had implemented them to fit this new customer acquisition tool.
Please note: Your market-facing teams do not need to be able to give a dissertation on the subject of privacy. They simply need to understand your organization’s high-level goals and—equally important—your organization’s commitment to comply with those goals. Your goals simply may be the top-level concepts of the Fair Information Principles, or they may be a subset that is more germane to specific products.
My advice is to keep the goals simple. To handle more substantive issues, keep an open line of communication to your sales, marketing and business development people. Basically, they should feel as though your door is always open if unusual or new situations arise or a partner/client has in-depth questions.
To be sure, having reasonable language in your template contract documents is a good start to ensure your organization stays on the right side of the privacy issue. But, let me end where I began: Training and engaging with your market-facing teams can extend the size and reach of your privacy/security programs at very little cost. And, in these times, who wouldn’t love to do more with less?
Lou Mastria, CIPP, is chief privacy officer and vice president of public affairs at NextAction Corp., a Westminster, Colo.-based provider of cooperative data solutions. He can be reached at (908) 363-0983, or by e-mail at firstname.lastname@example.org.