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Les Seagraves EarthLink, Inc.

Les Seagraves EarthLink, Inc. Beyond Your Privacy Policy: Developing a Comprehensive Privacy Plan. Les Seagraves, CIPP VP, Chief Privacy Officer & Asst. General Counsel EarthLink, Inc. Your Policy Should Cover:. Everything you do with personal information and what choices customers have

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Les Seagraves EarthLink, Inc.

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  1. Les SeagravesEarthLink, Inc.

  2. Beyond Your Privacy Policy: Developing a Comprehensive Privacy Plan • Les Seagraves, CIPP • VP, Chief Privacy Officer & Asst. General Counsel • EarthLink, Inc.

  3. Your Policy Should Cover: • Everything you do with personal information and what choices customers have • Helps to have External and Internal policies the same • Plan for the future

  4. Policy is great, now what ? • Everything else you do or say can become “policy” • Everywhere you deal with personal information needs to be part of a plan • Follow the data

  5. Following the Data • Advertising • Communicating to Non-Customers • Sign Up/Purchase • Using the Product or Service • Communicating to Customers • Customer Interaction • Ending the Relationship

  6. Everything about Privacy should be: • Easy • Obvious • Consistent

  7. Website • Collect information? • What do you say about it at the time of collection? (Obvious) • Choices? (Easy) • What actually happens? • Consistent with privacy policy? • 3rd Party Links? (Obvious)

  8. Marketing • Are there claims about information use? Should there be? • Clear what information is required? • Contests?

  9. Email to customers • Big issue because of different internal groups and uses • Effective Opt-out? (Easy) • Surveys • Categorize information = easy and obvious

  10. Registration • Account for every piece of information coming in • Storage • Paper records = destruction

  11. Customer Service • Real time interaction with a customer • Need good rules for what and how information is collected and used • Ask for MMN? password? (Consistent) • Warnings to customers? • Phishing?

  12. Public Relations • PR and Managers need to understand the intricacies of your policy • CEO speeches – be careful • Blogs

  13. Plan for a mess • What happens during a crises? • Are privacy rules still followed? • Are they “bent” in the name of urgency? • Practice scenarios over and over (Consistent)

  14. Questions? • Les Seagraves • les.seagraves@corp.earthlink.net

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