Best Practices For Implementing Data Privacy Policies

The Office of the Australian Information Commissioner has published the "Privacy Foundations Self-Assessment Tool" to help businesses evaluate and strengthen their privacy practices. This tool is designed for organizations that may not have in-house privacy expertise but want to establish or improve how they handle personal information. The tool is structured as a questionnaire and an action planning section that can be used to create a Privacy Management Plan. It covers key #privacy principles and offers actionable recommendations across core areas of privacy management, including: - Accountability and assigning responsibility for privacy oversight. - Transparency through clear external-facing privacy notices and policies. - Privacy and #cybersecurity training for staff. - Processes for identifying and managing privacy risks in new projects. - Assessing third-party service providers handling personal data. - Data minimization practices and consent management for sensitive information. - Tracking and managing use and disclosure of personal data. - Ensuring opt-out options are provided and honored in direct marketing. - Maintaining an up-to-date inventory of personal data holdings. - Cybersecurity and data breach response. - Secure disposal or de-identification of data when no longer needed. - Responding to privacy complaints and individual rights requests. This self-assessment provides a maturity score based on the responses to the questionnaire and tailored recommendations to support next steps.

How To Handle Sensitive Information in your next AI Project It's crucial to handle sensitive user information with care. Whether it's personal data, financial details, or health information, understanding how to protect and manage it is essential to maintain trust and comply with privacy regulations. Here are 5 best practices to follow: 1. Identify and Classify Sensitive Data Start by identifying the types of sensitive data your application handles, such as personally identifiable information (PII), sensitive personal information (SPI), and confidential data. Understand the specific legal requirements and privacy regulations that apply, such as GDPR or the California Consumer Privacy Act. 2. Minimize Data Exposure Only share the necessary information with AI endpoints. For PII, such as names, addresses, or social security numbers, consider redacting this information before making API calls, especially if the data could be linked to sensitive applications, like healthcare or financial services. 3. Avoid Sharing Highly Sensitive Information Never pass sensitive personal information, such as credit card numbers, passwords, or bank account details, through AI endpoints. Instead, use secure, dedicated channels for handling and processing such data to avoid unintended exposure or misuse. 4. Implement Data Anonymization When dealing with confidential information, like health conditions or legal matters, ensure that the data cannot be traced back to an individual. Anonymize the data before using it with AI services to maintain user privacy and comply with legal standards. 5. Regularly Review and Update Privacy Practices Data privacy is a dynamic field with evolving laws and best practices. To ensure continued compliance and protection of user data, regularly review your data handling processes, stay updated on relevant regulations, and adjust your practices as needed. Remember, safeguarding sensitive information is not just about compliance — it's about earning and keeping the trust of your users.

A court recently let a California CCPA class action lawsuit proceed against a company for its website's use of Google Analytics. Here's what to know and do ⬇️ A federal district court in California allowed a CCPA #ClassAction to survive a motion to dismiss. The defendant offers a website-based service for connecting people to mental health therapists, and allegedly allowed #GoogleAnalytics to collect information like mental health conditions entered into its website. Google offered an IP address anonymization feature that defendant allegedly didn't use.    The court ruled that the CCPA claim under its limited private right of action (Cal Civ Code § 1798.150) could proceed even though there was no data breach. It reasoned that a data breach isn't required--a claim could proceed if personal information is subject to unauthorized disclosure as a result of the business's failure to maintain reasonable security procedures (presumably the use of the Google IP address anonymization feature). While this isn't a ruling on the merits, the fact that the CCPA allows statutory damages of $100-$750 per consumer/incident (or actual damages if greater) could lead to claims against other companies on this theory for using cookies, pixels, and other tracking technologies for common business practices like #TargetedAdvertising and #website #analytics.   What should your company do? Here's four steps to consider: 1️⃣ Don't panic. This case isn't a ruling on the merits, and it's not clear this theory will ultimately prevail. 2️⃣ Assessments. Validate that your privacy or tracking technology assessment processes: 🔹Identify what data is passed by each tracking technology; 🔹Determine whether all data need to be passed & remove any that don't; and 🔹Use privacy-protective tracking technology provider tools and settings (Know what team at your company identifies what options are available, and determine whether they have the privacy knowledge to know what to look for and use. Reviews of providers’ documentation and settings are often needed.). 3️⃣ Governance. Establish or validate an approach to governing the use of tracking technologies on your company's website and mobile #apps, including: 🔹Keeping an up to date understanding of the technologies used and business purposes they serve; 🔹Knowing what specific data types are passed; 🔹Triggering reviews or re-assessments when there are changes to data passed or business purposes the technologies are used for; and 🔹Getting buy-in and alignment on roles and responsibilities with stakeholders that can place, use, or configure the technologies. 4️⃣ Consider Consent. Especially when website/app events or other data types passed could reveal something sensitive, obtain opt-in consent before allowing the data to be transmitted. This is viewed as required by the FTC, and is required under some of the state comprehensive #privacy laws.