This article was co-authored by partners Megan L. Brown and Matthew J. Gardner and associate Kathleen E. Scott, all members of Wiley Rein LLP’s Privacy, Cyber & Data Governance Practice.
As businesses adjust to the “new normal” in the ongoing COVID-19 pandemic, it is important to quickly take stock of where your organization stands on privacy and security risk. Even in these unusual circumstances, organizations of all sizes and sophistication continue to be expected to act with reasonable care and comply with their public commitments and regulatory obligations.
Enterprises may be finding different or better ways to operate, collaborate, and service customers. But state regulators, privacy advocates, class action lawyers, and the #twitterverse are ready to call organizations out, so it is prudent to think about your practices from the lens of a state or federal regulator or a customer. As a California official reportedly said, “We encourage businesses to be particularly mindful of data security in this time of emergency.”
Here are ten things to think about:
- Is your organization collecting information now that you were not before, or using existing data…
