SCENARIO
You have just been hired by Ancillary.com, a seller of accessories for everything under the sun, including waterproof stickers for pool floats and decorative bands and cases for sunglasses. The company sells cell phone cases, e-cigarette cases, wine spouts, hanging air fresheners for homes and automobiles, book ends, kitchen implements, visors and shields for computer screens, passport holders, gardening tools and lawn ornaments, and catalogs full of health and beauty products. The list seems endless. As the CEO likes to say, Ancillary offers, without doubt, the widest assortment of low-price consumer products from a single company anywhere.
Ancillary's operations are similarly diverse. The company originated with a team of sales consultants selling home and beauty products at small parties in the homes of customers, and this base business is still thriving. However, the company now sells online through retail sites designated for industries and demographics, sites such as “My Cool Ride" for automobile-related products or “Zoomer†for gear aimed toward young adults. The company organization includes a plethora of divisions, units and outrigger operations, as Ancillary has been built along a decentered model rewarding individual initiative and flexibility, while also acquiring key assets. The retail sites seem to all function differently, and you wonder about their compliance with regulations and industry standards. Providing tech support to these sites is also a challenge, partly due to a variety of logins and authentication protocols.
You have been asked to lead three important new projects at Ancillary:
The first is the personal data management and security component of a multi-faceted initiative to unify the company’s culture. For this project, you are considering using a series of third- party servers to provide company data and approved applications to employees.
The second project involves providing point of sales technology for the home sales force, allowing them to move beyond paper checks and manual credit card imprinting.
Finally, you are charged with developing privacy protections for a single web store housing all the company’s product lines as well as products from affiliates. This new omnibus site will be known, aptly, as “Under the Sun.†The Director of Marketing wants the site not only to sell Ancillary’s products, but to link to additional products from other retailers through paid advertisements. You need to brief the executive team of security concerns posed by this approach.
If you are asked to advise on privacy concerns regarding paid advertisements, which is the most important aspect to cover?
Aadhaar is a unique-identity number of 12 digits issued to all Indian residents based on their biometric and demographic data. The data is collected by the Unique Identification Authority of India. The Aadhaar database contains the Aadhaar number, name, date of birth, gender and address of over 1 billion individuals.
Which of the following datasets derived from that data would be considered the most de-identified?
SCENARIO
Carol was a U.S.-based glassmaker who sold her work at art festivals. She kept things simple by only accepting cash and personal checks.
As business grew, Carol couldn't keep up with demand, and traveling to festivals became burdensome. Carol opened a small boutique and hired Sam to run it while she worked in the studio. Sam was a natural salesperson, and business doubled. Carol told Sam, “I don't know what you are doing, but keep doing it!"
But months later, the gift shop was in chaos. Carol realized that Sam needed help so she hired Jane, who had business expertise and could handle the back-office tasks. Sam would continue to focus on sales. Carol gave Jane a few weeks to get acquainted with the artisan craft business, and then scheduled a meeting for the three of them to discuss Jane's first impressions.
At the meeting, Carol could not wait to hear Jane's thoughts, but she was unprepared for what Jane had to say. “Carol, I know that he doesn't realize it, but some of Sam’s efforts to increase sales have put you in a vulnerable position. You are not protecting customers’ personal information like you should.â€
Sam said, “I am protecting our information. I keep it in the safe with our bank deposit. It's only a list of customers’ names, addresses and phone numbers that I get from their checks before I deposit them. I contact them when you finish a piece that I think they would like. That's the only information I have! The only other thing I do is post photos and information about your work on the photo sharing site that I use with family and friends. I provide my email address and people send me their information if they want to see more of your work. Posting online really helps sales, Carol. In fact, the only complaint I hear is about having to come into the shop to make a purchase.â€
Carol replied, “Jane, that doesn’t sound so bad. Could you just fix things and help us to post even more online?"
‘I can," said Jane. “But it's not quite that simple. I need to set up a new program to make sure that we follow the best practices in data management. And I am concerned for our customers. They should be able to manage how we use their personal information. We also should develop a social media strategy.â€
Sam and Jane worked hard during the following year. One of the decisions they made was to contract with an outside vendor to manage online sales. At the end of the year, Carol shared some exciting news. “Sam and Jane, you have done such a great job that one of the biggest names in the glass business wants to buy us out! And Jane, they want to talk to you about merging all of our customer and vendor information with theirs beforehand."
When initially collecting personal information from customers, what should Jane be guided by?
What is typically NOT performed by sophisticated Access Management (AM) techniques?
When releasing aggregates, what must be performed to magnitude data to ensure privacy?
What can be used to determine the type of data in storage without exposing its contents?
What must be done to destroy data stored on "write once read many" (WORM) media?