Protecting personal information stretches far beyond keeping your credit card close to your chest. Companies need to take care of privacy issues, as most handle scores of personal and other sensitive information about customers, clients, employees, and the company (e.g, trade secrets, proprietary information, intellectual property).

Think about what would happen if one of your competitors had access to your systems, or if an employee cracked into the Human Resources database and snooped around at information in other employees' files. Doesn't really sound like something you want happening within your organization, does it?

Companies are up against an ever-changing list of internal and external security threats. Cybercriminals are getting smarter and more sophisticated every day, and with innovations in technology, it's getting easier for anyone to become a data thief. Depending on who you ask, some people say that your biggest corporate security threats come from within the organization.

So, how do you handle this? What can you do to protect the information you store and handle in your company? Here's how to write a privacy policy that protects your company's sensitive data from bad internal actors (employees).

Writing Your Internal Privacy Policy: A Quick Guide

As with most issues in the workplace, start with an internal data privacy policy. A policy guides employee behavior and can even help prevent data breaches.

Your company's internal privacy policy should cover areas such as:

• Employee records- personal information, medical history, employment history, etc.
• Email and Internet usage guidelines - what sites and behaviors are forbidden on company devices and time
• Handling client/customer information - who can access this? How should it be stored? What are your deletion protocols?
• Internal systems and access- permission, responsibilities, access to files, etc.
• Mobile devices- company phones, laptops, and other devices and their disposal
• Established laws and regulations - what data privacy laws is your organization subject to? What are their requirements and who is responsible for carrying those out?
• Consequences for violating the policy - include disciplinary actions for each offense, if applicable
• Reporting a security breach - what steps need to happen? What order will they happen in and what is the timeline? Who is responsible for which steps?
• Internal data privacy policy GDPR requirements if you are located in the EU or handle data of EU citizens

It seems like a lot to cover, and it is, but these are all important topics that require significant consideration. If your company uses any sort of employee monitoring, such as web surfing or telephone monitoring, communicate this in the policy and make employees aware that there are measures in place to ensure compliance with the policy.

To get started, look at some internal privacy policy examples that other companies have written. Try to find an internal privacy policy for employees example from a company that is in a similar industry and comparable size. You can even find an internal privacy policy template to streamline the process!

Does your code of conduct cover all the bases, including accessing sensitive internal data? Download the free Code of Conduct Template to make sure and to write a document that keeps up with best practices.

The Nitty Gritty of a Corporate Privacy Policy

When writing your internal privacy policy, don't leave room for employees to speculate or assume. If you think you have to "spell it out" to your employees, do so. Include real-life examples of situations that could (or have) occur in your workplace. There are a ton of great resources out there to provide you with an example of a privacy policy. The Privacy Rights Clearinghouse offers a number of resources, including a checklist for handling information. The checklist discusses privacy policies and important questions to ask when writing your corporate data privacy policy.

Some of the questions on the checklist include:

• "Do all employees follow strict password and virus protection procedures?
• Are employees required to change passwords often, using "foolproof" methods?
• Is encryption used to protect sensitive information (a particularly important measure when transmitting personally-identifiable information over the Internet)?
• Do you regularly conduct systems-penetration tests to determine if your systems are hacker proof?
• Do you have staff specifically assigned to data security?
• Do staff members participate in regular training programs to keep abreast of technical and legal issues?
• Have you developed a security breach response plan in the event that your company or organization experiences a data breach?
• Have you developed security guidelines for laptops and other portable computing devices when transported off-site?
• Is physical access restricted to computer operations and paper/micrographic files that contain personally identifiable information?
• Do you have procedures to prevent former employees from gaining access to computers and paper files?
• Are sensitive files segregated in secure areas/computer systems and available only to qualified persons?"

In addition to these questions, it's important that employees know how to report a suspected or known security breach. Whether it was an accident such as sending an email to the wrong contact or overhearing about an employee selling sensitive company information, every incident needs to be reported. In the internal privacy policy for employees, include a list of phone numbers, email addresses and any other contact information employees can use to report a security breach.

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Frequently Asked Questions

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