with Jennifer Albornoz Mulligan, Laura Koetzle, Sarah Bernhardt
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Executive Summary
Create your firm's privacy program based on the following fundamentals: 1) Limit data collection; 2) ensure data quality; 3) reveal the purposes behind your data collection; 4) limit your use of the data to those purposes; 5) implement reasonable security measures; 6) be open about your principles with your customers, as well as with your employees; 7) give the subjects of the records all possible access to their data; and finally 8) hold yourself accountable for meeting these guidelines. Simply stating the policies won't get the job done; you must make sure that your corporate culture and values support your whole privacy program.
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