Finger pressing smartphone with information shown as secure with a lock, customer data compliance plan

How to Create a Customer Data Compliance Plan

Marketing and selling in the Internet Age generally involves the use of internet cookies, which makes predicting customer behavior easier.  Businesses then use this more personalized approach to tailor offerings specifically to the buyer in the name of an improved customer experience.

In order to participate in this system, however, the customer must trade a little of his/her private information.  Often the customer is not aware of this process, and some privacy groups have argued that the individual, not the company, should be fully in charge of said information.

You want to be the kind of business that your customers can trust so getting this right is crucial – but how do you begin?  Fortunately, I have created these key steps to help you create your Customer Data Compliance Plan.


First: Consolidate Your Customer Databases

Think of all the customer data your organization collects each day.  Marketing collects customer information.  So does Sales.  Where do these updates go?  Are new records created every time a department makes a new customer data entry?

Now think of the ever-changing landscape regarding data privacy.  Earlier we discussed entity resolution, a process that captures all your data, cleans and de-duplicates it, and creates a “golden” record for each customer.  If your goal is to build a system of protection and governance around your customers’ data, you must know where that data resides and get it cleaned up first.  Make sure entity resolution is the first step in your strategy.


Second: Select a Consent Management Platform

Establishing your Consent Management Platform (CMP) should be your next priority.  Cookie consent policies are now widely used, helping customers gain better control of the type of information shared with a company.  Now that you have your customer data organized, it is easy to then map it to a consent management policy.

Make sure you have the following best practices employed in your CMP:

  • Ability to block third parties
  • Adjust to the geography and language of the user
  • Store customer information securely


Third: Create a Data Subject Rights Management Portal

GDPR, CCPA and other data privacy regulations govern the rights individuals have regarding their data.  So, take your clean database and your new CMP and add a Data Subject Rights Management (DSRM) Portal.

Your DSRM Portal should help tackle the following data privacy concerns:

  • Verify the data subject’s identity
  • Assign requests to the correct owner in your organization
  • Delegate data source retrieval
  • Deliver the results of the request to the data subject within required timelines

Find a system that utilizes Artificial Intelligence but doesn’t solely depend on it.  AI recommendations should still be checked by human intervention to ensure your complete compliance with any regulation.


Fourth: Consider Vendor Risk Monitoring

Conducting business often means partnerships and dealings with third parties.  How a customer’s data is transmitted from your organization to a third party is also an important responsibility.  If you are a service organization, you are probably already familiar with SOC 2 requirements around the five trust service principles of Security, Availability, Processing Integrity, Confidentiality and Privacy.  SOC 2, GDPR and the like have now made vendor monitoring a requirement.

As you build your Customer Data Compliance Plan, consider ways to automate vendor monitoring to ensure better accuracy with less manual effort.  Choose a solution that helps you:

  • Track and provide alerts to changes in vendor risks/privacy ratings
  • Identify risky vendors – should you consider a safer partner instead?
  • Follow the data to see what they are doing with your customer’s information
  • Get alerts on any new vendor lawsuit if filed (instead of waiting on media reports)

In case you are wondering if you should include vendor management, consider this important detail:  should charges ever be brought up against your company, the Department of Justice will want to know if/how you are monitoring your vendors!


Finally: Complete your Customer Data Compliance Plan

Now that you have committed to all of the steps above, don’t stop there!  Complete the process by adding the following elements:

  • GDPR Representation: Doing business in Europe and don’t have a physical location/office there?  Consider employing a GDPR Representative to take care of that requirement for you.
  • Privacy Law Alerts: Automatically keep up with changing laws in multiple geographies.
  • Access to Privacy Experts: Unlimited and on-demand access to a privacy attorney when you have a question


Where Can I Get Help?

Privacy laws are everywhere.  From GDPR to LGPD, from CCPA to the next state’s legislation, keeping up with customer data privacy regulations can be a full-time job.  This trend will only increase, and you need a plan that can adapt to this ever-changing environment.

Even if you do not do business in Europe, Brazil, or California, you should still consider creating a Customer Data Compliance Plan, simply for building more trust with your customers.  If they see you are serious about their private information, they will trust you with their business.

What is your biggest concern when it comes to data privacy?  Miller Operations has the tools to help you build your plan – from entity resolution through data compliance systems.  How can we help?  Schedule your free 30-minute call today.

Image by Pete Linforth from Pixabay

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