How to Build a Privacy and Cyber Security Program (Nonprofit Edition)

 

While many in the nonprofit community believe that a privacy and cybersecurity program is beyond their means, the fact is there are many ways to tackle this problem—many of which are low and no cost—and most of which is low-tech. And the cost of doing nothing is very high. In the highly competitive world of nonprofit reputation management, the consequences of a breach can be absolutely devastating.

I enjoyed presenting on this subject to a lively and engaged crowd at the NTEN Nonprofit Technology Conference with my colleague Raf Portnoy.

  • Session details here
  • Slides here 
  • Participant’s notes from our presentation are here.  

Privacy + Security Forum

Update  (10/29/16): Here is the slide deck Bret and I presented.

I am pleased to be speaking at the Privacy + Security Forum this week.  The agenda is packed with great topics — and it is clear that the employment relationship will be discussed throughout.  At the same time, only two sessions deal exclusively with the employment relationship:  one discussing on pre- and post-employment background checks (Combating the Insider Threat:  Background Screening and Monitoring) and the one I am leading, Privacy and Security in the Employment Relationship.  This tells me that the centrality of the employment relationship to the security and privacy realm is not yet fully understood to practitioners.

I am grateful to Professor Solove for the opportunity to share my views on the topic – and I look forward to being joined by my co-presenter, Bret Cohen at Hogan and Lovells!

The EU GDPR for US Employers: Practice Tips

The new EU GDPR will be a game changer for a number of multinational employers.  Here are a few practice pointers for US-based enterprises with European HR data:

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“Live Blog”: Data Breach War Room / Breach Preparation

As mentioned, I am a panelist at today’s “Data Breach War Room / Breach Preparation” at iTechLaw’s 2016 World Technology Conference in Miami.  I will be “live blogging” the key lessons from today’s workshop.  My co-panelists, Meg Strickler, Jon Neiditz and Mark Mermelstein, will have the chance to review this content, but until they do, I am solely responsible for its content.   Here goes:

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Data Breach War Room / Breach Preparation

Excited to be joining a distinguished group of lawyers to present a highly-interactive workshop called “Data Breach War Room / Breach Preparation” at iTechLaw’s 2016 World Technology Conference in Miami.

As readers of this blog know, I often write about planning for a breach. One key element of planning is practice: testing your plan.  You can test a plan in different ways, including under the real pressure of an actual incident (a bad idea), through a table-top exercise and by the use of routine scenario testing hypothetical.  Real world testing is bad for obvious reasons: you may find yourself without a workable plan at all.  Table-top exercises involve a formal, sit-down and walk-through*  where your plans are pressure-tested against an evolving (fictitious) scenario.  In the best case, all of the “actual” players are there and the scenario is spun by an outsider with little connection to the politics of the organization. Routine scenario testing involves building a cultural norm of asking “what if” questions — and answering them within the framework of your plan.

Regardless of how your plan is tested, it is essential that your plan have a feedback mechanism to receive, record and consider the honest results of the test.

 

*- I say “walk-through” because it is essential that folks not only drill on the plan, but that they know the physical spaces they are using to execute the plan.  Perhaps your “war room” needs to have a non-VOIP phone.  …or be larger…or be closer to the CEO’s office…or closer to a bathroom.  It is often quite interesting to see what comes to light when you actually move through the spaces you plan to use!

Building a Privacy Program, Part 2

Earlier this month, I wrote Building a Privacy Program; today I appeared in Epstein Becker Green’s Employment Law This Week to discuss the the topic:

EELAW

The full video can be found here (and the Tip of the Week starts here).

 

Building a Privacy Compliance Program

I take the (perhaps uncontroversial) view the privacy and security are intertwined.  While easier said than done, here are some steps for establishing a privacy compliance program.

Continue reading “Building a Privacy Compliance Program”