Considering recent guest information privacy policy violations by the
staff members at Padgett-Beale, Chief Privacy Officer has asked to
for improvements in staff awareness and training, so that privacy
violations do not reoccur in the future. All employees will
understand personally identifiable information, privacy by design,
and acceptable use policy from the updated training. The internal
training program should address the seriousness of the violations of
guest’s personally identifiable information It should cover possible
consequences, not limited to suspension and termination of the
guilty party, but also include the legal ramifications from the
victim(s), the organization, and/or the state and local governments.
By updating the training to include personally identifiable
information, privacy by design, and acceptable use policy with
outline of punishment, all employees at Padgett-Beale should
understand the magnitude of protecting customer information.
c c The employees must first understand what personally
identifiable information, otherwise known as PII, is. According to
Bernstein (2021), PII is “any data that could potentially identify a
specific individual”. This include, but not limited to, name, address,
email, telephone number, date of birth, credit or debit card, and any
other information about the customer that is collected at Padgett-
Beale properties that can identify a customer. At Padgett-Beale, PII
information is handled at point of sales, reception, and by our cooks,
and should be limited to those who require such information to
conduct business behalf of Pagett-Beale as guest service. Employees
should be aware, like others in the industry, Padgett-Beale does not
collect information of children under the age of 16 (The Leading
Hotels of the World, 2021). All employees should understand the
protection of guest PII is responsibility of all personnel at Padgett-
Beale, and the consequences for violators should be outlined in PII
training, as well as in acceptable use policy. In protecting PII, the
organization should state its adherence to Privacy by Design
principles.
c c Padgett-Beale protects customer PII by adhering to
Privacy by Design. According to Kroener and Wright (2014), Privacy
by Design Principles was pioneered by Commissioner Ann
Cavoukian at Ontario Information and Privacy, advocating
proactiveness in protecting privacy. Not only is IT infrastructure
important in protecting customer privacy from outside threats, but it
is also important that privacy taken seriously from point of sales to
data retention. The employees handling PII, needs to understand
that they are a part of the Privacy by Design at Padgett-Beale, and it
involves all employees in proactively protecting customer PII.
Privacy and protection of information is the responsibility of entirety
of the organization, and consequences should also be highlighted in
the training.
c c Padgett-Beale, in it’s revamped training, needs to include
acceptable use policy for all employees. This should cover what
information is privileged information, and who has access to this
information, as well as the consequences of violating the policy.
AUL, should clearly outline the responsibilities of those who handle
PII, and types of behaviors that are discouraged in handling sensitive
information. It should also outline what data is protected by the
organization and subject to suspension or termination, and data that
is protected by law and subject to prosecution. The AUP should be
signed by all employees and included in their employee file as part of
their training and employment requirement (BioMelbourne Network,
2020).
c c With the revamped Padgett-Beale employee training, all
employees should understand the importance and the consequences
of violating privacy policies of the organization. They should be
aware of the terms such as PII, Privacy by Design, and Acceptable
Use Policy of the organization. -Beale management team will see the
reduction in the violation of customer privacy as all employees
become familiarized with the consequences of their actions.
References
Bernstein, C. (2021, September 24).
personally identifiable
information (PII)
. Tech Target.
https://www.techtarget.com/searchsecurity/definition/personally-
identifiable-information-
PII#:%7E:text=Personally%20identifiable%20information%20(PII)%2
0is,anonymous%20data%20is%20considered%20PII.
BioMelbourne Network. (2020, January 27).
Importance of
acceptable use policy – IT Systems & Services
.
https://biomelbourne.org/importance-of-acceptable-use-policy-it-
systems-
services/#:%7E:text=An%20acceptable%20use%20policy%20(AUP,b
eing%20granted%20a%20network%20ID.
Kroener, I., & Wright, D. (2014). A Strategy for Operationalizing
Privacy by Design.
Information Society
,
30
(5), 1.
https://doi.org/10.1080/01972243.2014.944730
The Leading Hotels of the World. (2021, May).
The Leading Hotels
of the World Privacy Policy
. https://www.lhw.com/Privacy-Policy
