Adapting Privacy Training to Evolving Regulations

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It’s a well-known fact that employees love any and all training sessions. A particular favorite, according to internet sources, is privacy training.

Just kidding. 

Employee training is a frequent source of office jokes and memes. Maybe it’s a topic people don’t take seriously, or maybe the training video hasn’t been updated since 1998. 

That’s fair.  

But while employee training can get a bad rap, training is there for a reason. Employee data privacy training is critical to protecting your company, consumers, and employees. 

So, when we talk about data privacy training, it’s important to consider it from different angles:

  1. How can you adapt your employee data privacy training to stay relevant and up-to-date amidst evolving regulations?
  2. How can you make the training as effective and engaging as possible?

Let’s talk about it.

The different types of employee data privacy training

Privacy training is not a one-size-fits-all situation. The necessary training will depend on the regulations specific to your industry, location, audiences, services or products, and data collection activities, not to mention the different departments and roles within your organization. 

Despite these nuances—or maybe because of them—training works best when it takes place on multiple levels. 

Company-wide training

Data privacy involves everyone in an organization, no matter their role. As such, company-wide data privacy training programs should provide the broadest overview of data privacy and security:

  • What is data privacy
  • What is data security
  • Why both data privacy and data security matter and how they intersect
  • Legal requirements surrounding personal information
    • Overview of privacy laws
    • How employees should think about collecting, using, sharing, and storing personal information
  • Data access and handling procedures
  • Role of data protection at your company

Training should start with onboarding new employees, but that shouldn’t be the only time it comes up—for several reasons. 

To start, privacy can be a hard topic to wrap one’s head around. It’s far more likely employees will retain information if you break it up into manageable chunks and deliver it over time.

Additionally, while it helps to pencil a training update into your calendar for current employees, remember that privacy laws are enacted throughout the year. Don’t wait for that one day in November to provide an update. Provide training continuously and update training modules as new regulations roll out. (Because they will!)  

Role-based training

It would be impractical to expect each employee to know everything about data privacy. 

Thankfully, they don’t need to. Different teams and departments handle data differently within your organization. Your HR department needs to know different things than your marketing or legal team. 

Herein lies the beauty of specialized, role-based training. Role-based training provides targeted information to the people who need it for their job functions.

Here are some areas of specialized training you may need to consider for your business. Note that these are broad strokes—each business has its own unique structure. Anyone who processes data needs training, so make sure these employees are getting connected to the proper training. 

  • Finance: Payroll employees may need advanced training on data security and fraudulent activity. They may require specialized training on how to handle bank account details or how to spot a phishing attempt. 
  • Human resources: HR folks handle an incredible amount of sensitive employee data daily. Many regulations have specific requirements for employee data processing that your HR team needs to understand.
  • Legal and compliance teams: Legal departments need a deep understanding of privacy laws like GDPR and the increasing roster of state privacy regulations like the California Consumer Privacy Act (as amended by CPRA), Utah Consumer Privacy Act, New Jersey Data Privacy Act, et al. Training should emphasize accountability and ethical implications to prevent mishandling of personal data and support company-wide compliance.
  • Marketing: Just like legal and compliance teams, marketing professionals need comprehensive training on various privacy laws for compliance, as well as privacy best practices like data minimization, consent principles, and individual rights in marketing activities such as targeted marketing. Training should cover data security, bias, and ethical considerations in handling data, especially when using AI.
  • Customer service: Employees who work in customer service interact with a wide range of private customer information daily. Customer service teams must understand how they can or cannot use, share, or process customer data. They should also be aware of how to process individual rights requests in line with compliance requirements. 

Individual training

While most people can receive training in small groups, some individuals in your organization may require advanced individual training. This typically includes privileged users and executives

  • Privileged users are employees with access to and interaction with a greater range of personal data. As such, these users typically require advanced privacy reviews so they have the appropriate protocol for interacting with that data. With great power comes great responsibility (and a bit more employee training). 
  • Executives and executive assistants may also require advanced training because of their level of access to personal data. Executives also manage large teams, and it’s their responsibility to reinforce privacy standards across the organization. (It’s a monkey-see, monkey-do situation.) Additionally, because executives make big-picture decisions for their company, understanding privacy will improve their context for the intersection of privacy and business practices. 

Cookie review training

Unfortunately, this is not the fun “someone brought cookies into the breakroom” situation. Digital cookies have been a hot-button topic in data privacy for several years, and the regulations continue evolving. Just as importantly, business and tech leaders continue to evolve in their usage of them. (Take Google’s plan to begin blocking third-party cookies in 2024 as an example.)

Cookie training may be necessary for anyone who interacts with your website, from the marketing team to the website developer. Training may cover topics such as:

Data inventory training

Data inventories should be a regular occurrence in your organization. Data inventories provide a bird’s eye view of your organization and help you spot any vulnerabilities or inefficiencies in your system. 

Because the privacy landscape—and the data in your systems—can change so rapidly, guidance is a smart measure to take. A third-party expert can provide specialized training on effectively managing and maintaining data inventories. 

Location-based data privacy training

Some jurisdictions specifically require employee privacy training.

For example, the California Consumer Privacy Act (CCPA) specifically requires privacy training for specific individuals within a company. Under the CCPA, employees responsible for handling consumer inquiries about your company’s privacy practices have to be able to help consumers if they choose to exercise their rights under the CCPA. 

Which, okay, is a little self-explanatory. If you handle customer privacy inquiries, you have to know about the regulations related to customer privacy and what you can or can’t discuss. 

If you’re ever confused about how much training an employee needs, you can err on the side of caution and consult a third-party expert. 

On the other hand, the EU’s General Data Protection Regulation (GDPR) may require separate training within your organization. Most U.S. state regulations are at least in part inspired by the GDPR, but there are some significant differences. Notably, the GDPR does not have the same threshold exemptions for small businesses common in the U.S., so even if you are a small business, you are still expected to comply with the GDPR.

If your business targets EU residents, then your company is required by the GDPR to provide employee data privacy training. 

Five tips to make your employee training engaging AND effective

So you have a general idea of what training you need to provide. Now what? Now, you have to get your employees to care. 

Here are some ideas to engage your employees in privacy training:

1. Show them the carrot.

Take the time to explain to employees why data privacy is a good thing. For different teams, this may require different strategies. Talk with your marketing team about how data privacy builds trust with leads and customers and provides a fantastic differentiator for your business. With your legal team, discuss how compliance minimizes their paperwork.  

Show your team how data privacy training can make their job easier or their work more effective, and they’ll pay a lot more attention. 

2. Show them the stick.

There are plenty of benefits to employee training. There are also plenty of risks associated with employee non-compliance.

 While fear-mongering may not work on its own, explaining the significant risks and liabilities of data privacy violations can underscore the importance of the training and why it matters to the company’s overall success. 

3. Don’t try to teach them everything

Yes, more information is generally better. However, it may be worse for their attention span and enthusiasm for the subject. 

You don’t have to share every nuance of the GDPR or the CCPA. Teach them what they need to know for their roles, and layer on more information as necessary. They’ll retain more, and they won’t dread sitting through a 90-minute presentation.

4. Solicit employee feedback.

There is always room for improvement in any organization, and that includes the training process. Solicit feedback from your employees to understand what worked, what didn’t, and how you can make the training better for employees going forward. 

Feedback can also look like asking them about opportunities they see. As they learn more about privacy, they can identify gaps in processes and opportunities to build better products, increase consumer trust, and incorporate privacy into the workplace culture.

5. Don’t stop training

You’ve identified who needs training. You’ve tailored it to their exact roles. You’ve crafted your sales pitch to get employees invested. You’ve gotten feedback and incorporated it. 

Now get ready to do it again—and don’t wait. 

At the risk of sounding like a broken record, privacy is ever-changing. If you plan your training annually, it will be outdated before the end of the quarter. And outdated training? It leads to bad privacy outcomes. 

A better option: make training ongoing, multifaceted, and sponsored by executive teams. Sure, having a big once-of-year privacy training where you talk about initiatives and goals is fine, but supplement it with regular privacy check-ins. These should be based on: 

  • What kind of data your business collect
  • Compliance requirements
  • Product and service line changes

Training doesn’t have to be delivered in a big auditorium followed by stale bagels and weak coffee, either. Get creative with how you deliver training. 

If you’re a tech startup with a killer design team, incorporate gamification with a fun branded animation. If you’re a large enterprise, develop a polished corporate video or bring in privacy industry speakers to speak to small groups for a more intimate experience. Encourage executives to talk about the impact privacy practices can have—and are having—on the business in concrete teams. 

When you incorporate engaging delivery, relevant information, and top-down buy-in, you’ll have greater retention and greater enthusiasm.  

Build an employee training program for your business’s unique needs.

Employee training doesn’t have to be crazy or complicated. Red Clover Advisors builds privacy training programs for businesses of all sizes. Schedule a free consultation call to explore how we can help your team get on top of privacy and get back to business.