This post originally appeared on the Connecticut Employment Law Blog.
Last night I had the opportunity to speak to the Colonial Total Rewards Association on the topic of Data Privacy and HR. I titled the presentation “Is Your HR Data Going Rogue” and really focused on the role that Human Resources professionals should play in ensuring that company data is secured.
Even technology companies are not immune. My favorite blurb from the last month was the following:
On Thursday, March 16, the CEO of Defense Point Security, LLC — a Virginia company that bills itself as “the choice provider of cyber security services to the federal government” — told all employees that their W-2 tax data was handed directly to fraudsters after someone inside the company got caught in a phisher’s net.
So if even tech companies are victims of data breaches, is there any hope for the rest of us? Well, yes. It’s not easy but there are several steps that employers can take.
- Learn – This is NOT simply IT’s role; rather, HR professionals should have a key role at the table in discussing a company’s data privacy culture and practice. And the first step in that is that HR should learn the basics of data privacy.
- Assess – HR has access to lots of data; where is it and who has access? Where are you “leaking” data when it comes to your employees?
- Develop – Develop policies and your data privacy program; and develop the teams of people that will respond in the event of a data breach
- Educate – Data privacy and protection ought to be part of sustained training program, just like anti-harassment training
- Monitor – Figure out risks and review areas; when breach happens, HR needs to be at table to discuss employee impact
- Inform – When (not if) if you have a data breach, inform those affected and gov’t officials and implement your data breach plan.
Once you’ve made it through, it’s time to start back at the beginning. Learn from your mistakes in a data breach and re-assess your vulnerabilities.
Data privacy and the need for companies to view it as a key part of your company’s culture should be an integral part of your employee onboarding and training. My thanks again to CTRA for the invitation to speak to the group and the great conversation we had last night.