Thursday, February 16, 2017

Privacy Guidelines: Consent, Purpose, and Retention

Guidelines: Consent, Purpose, and Retention

Part of: Privacy Guidelines
OverviewBuilding a set of Guidelines for Security and Privacy

Below are the guidelines for privacy with the elements of consent, purpose and retention. Whenever organization is mentioned, you can read businesses, healthcare and government. Whenever people is mentioned, you can read customers, consumers, employees, patients and clients. Data in this case is in the category of Personal Identifiable Information (PII) which is subject to national and EU law and regulations.

Only collect with consent

Data is only collected with consent of the subject of the data.

Meaning that you don't collect explicit or implicit data on people without them knowing about it and without the consent of them to do so.

Only collect for purpose

Data is only collected for the business function that it is strictly needed for.

In essence, make sure that you don't over-collect data about people. Data that is not needed for the business to operate is data that should not be collected.

Destroy after use

Data is only kept for the time that it is strictly needed for the processing or as required by law.

Don't keep data about people longer than is needed for the purpose. Whenever the organization-people relation has ended, delete the data. Just keep the data that you are required to by law. Make sure the retention time is within those boundaries.

Only enrich within purpose

Data enrichment is only done within the context of the initial collection and consent of the data.

You can profile and track people to an incredible extent. Beside that you need consent for this profiling, the profiling itself my not excessively step outside the boundaries of the purpose of your organization.

Designate Data Ownership

Data always has an owner, or at the least a steward, who upholds the Security Guidelines and Standards.

Data, just as systems and services, need an owner. Data can travel through many systems and although all those systems might have owners, the actually can't own the data because it is shared. When data has an owner, it can have the proper attention it needs for things like consent, purpose and retention.
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