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E-Privacy:
A Policy Approach to Building Trust and Confidence
In E-Business

Stage 4: The Pursuit of Excellence in E -privacy

10.1

The final stage in the E-Privacy Policy framework addresses three issues: the management of E-Privacy risks, the enhancement of compliance procedures, and the provider's commitment to continuous improvement. E-Privacy Policy is not only about engaging a systematic approach to online personal data privacy but is also concerned with the evolution of that approach to protect against new vulnerabilities. A long-term commitment to continuous improvement of systems security and the competencies of operational personnel is essential if new challenges are to be effectively countered.

10.2

Many providers have developed measures that have the power to raise the bar in respect of E-Privacy standards. Among these measures three in particular are worthy of note.

  • Risk Assessment and Review Procedures
    These procedures are designed to map security threats to the system. The better these threats are understood the more informed providers will be in terms of the controls that need to be applied to counter those risks. Risk assessment and review should become the raw input for better decision-making in respect of the integrity of the system, and the confidentiality of customer information stored
    in databases.
  • Vulnerability Assessment and Review Procedures
    These procedures may be engaged during prototype systems testing, when piloting the website, or when the systems architecture is upgraded. Essentially the procedures use software to review systems capabilities with a view to discovering vulnerabilities or potential weaknesses so that preventative measures can be taken.
  • Incident Reporting Procedures
    The nature of system breaches e.g. hacking into databases, is such that it is not possible with complete confidence to predict where and when an attack will come from. It is therefore necessary to develop a means of policing network traffic to report on intrusions, or the suspicion of intrusion, and establish rapid-response protocols to deal with these situations. Damage control procedures have a direct value, in that they seek to minimise adverse effects, and an indirect value, in that they provide valuable lessons that can be built into training and future systems design.

10.3

The rate of change in IT means that new developments in software pose a continuous, if not growing, threat to system integrity and, by extension, to E-Privacy. Inevitably there will always be a small minority in the IT community that feel the need to demonstrate their 'skill' by penetrating 'secure' systems. And some will succeed. If providers wish to reassure their customers that their policy towards E-Privacy is uncompromised by such activities then it is incumbent upon them to install, maintain and enhance compliance procedures that will enable them to deliver on that assurance. This has been understood by marketers of goods and services in the physical marketplace where manufacturers and retailers have endorsed their brands with extraordinary guarantees. These amount to a supreme level of confidence in the ability of the brand to satisfy consumer needs. In the cyber marketplace, for brand, read website. The challenge is for providers to be able to offer extraordinary guarantees that personal data privacy will not be infringed. To do that with any plausibility means that providers will need to uphold the letter of those guarantees and offer restitution if, and when, the conditions are violated. That is something that some may be reluctant to do because of the responsibility it places on the provider. However, that sort of thinking by providers will typify excellence in E-Privacy.

10.4

All systems thinking is premised on the understanding that a change in one part of the system will influence related part(s) of the system. It is conceivable therefore that in spite of the sophistication of IT systems and protocols E-privacy may be breached intentionally, or unintentionally, by the staff operating those systems. It is important therefore to sustain systems integrity by supplementing the processes outlined with a commitment to human resource training and development. The important point here is to recognise that no matter how well a training programme is designed and executed the real test of its effectiveness lies in the transfer of that training to the workplace. This means that good supervision,
and perhaps appropriate rewards, need to be part of the formula.


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