Think of all the detailed personal data your organization collects during the course of business. From biometric authentication data and workplace surveillance to customer transaction records, the modern enterprise collects more sensitive data than ever before. This reality raises serious ethical and privacy considerations that extend well beyond legal compliance.
Privacy is no longer just a legal obligation. It’s a defining factor of organizational trust. People want to know if their data is handled ethically, not just in a compliant manner. Whether you’re building a privacy program or refining one, it’s essential to embed ethical decision-making into every stage of the information lifecycle.
Accuracy, transparency, fairness, and purpose limitation are ethical principles that should guide every data-handling decision. Organizations that treat personal data with care and respect not only avoid legal risk, but they also build better relationships with their employees, clients, and partners. The following are a few key ethical best practices that your privacy program should incorporate across the information lifecycle.
Information should be collected directly from the person it pertains to. If data is gathered on behalf of a minor, a dependent, or for investigations, the source must be reliable. Ethical accuracy means ensuring decisions made about individuals are based on correct and complete data. Ask individuals to verify what’s collected or confirm its source. Poor accuracy can result in missed services, incorrect profiling, or denial of benefits to which they are otherwise entitled.
People expect to know when, why, and how their information is being collected. Under laws such as the GDPR, CCPA, and HIPAA, providing notice of information collection and obtaining consent are requirements. Collection notices should clearly state the purpose, what’s being collected, and who to contact with questions. Ethically speaking, failing to provide notice about collecting someone’s personal information will be perceived as deceptive, regardless of the intention.
Data should only be used for the purpose originally disclosed. Sharing personal data with other departments or external partners for purposes unrelated to their intended use often violates ethical standards and privacy laws. Your privacy program must define clear boundaries: who can access what information, and why. Even if sharing could improve efficiency, it must be weighed against privacy obligations.
Protecting personal data from unauthorized access is both an ethical responsibility and a legal necessity. Security controls should be designed into systems from the beginning, not added as an afterthought. Role-based access, encryption, and automation can help minimize the risk of human error while ensuring compliance. For example, a person with secure access to information should not have to think twice about if they can send a specific document to another person. Rather, the system should allow or deny sharing based upon established privacy standards.
Physical records also require careful handling. Files should be stored securely and accessed only by personnel with the appropriate clearance. Regular training is essential to ensure that staff are knowledgeable about handling sensitive documents. If using an off-site storage provider, confirm that they adhere to strict security protocols through regular audits. Upholding the highest standards for safeguarding information reinforces your ethical responsibility to stakeholders both inside and outside the organization.
Amanda Cavanah, Senior Director of Compliance & Risk Management at Access, recommends working with a storage vendor that is PRISM Privacy+ certified because it shows “that the service provider operates under strict controls designed to reduce the chances for mishandling of information, which could lead to data breaches.”
How long you store or retain personal information should depend on applicable regulations and your business. Over-retention may contravene regulations and expose the information to an increased risk of inappropriate access. The ethical choice is to ensure that personal information is only retained as long as necessary, and no longer. In some cases, this may also mean quickly and completely responding to an individual’s request to be forgotten and removing their information from all of the organization’s storage locations (physical and electronic).
During disposition, it’s critical that personal information is not exposed to parties who should not have access. Organizations should conduct due diligence with their secure destruction vendor to ensure they have controls in place that prevent unauthorized access. An easy way to do this is by verifying that the vendor is NAID certified, which requires them to prove on a regular basis that they’re compliant with local, state, and federal laws concerning data protection and destruction.
Privacy training and communications should begin at the hiring stage and continue regularly thereafter. All employees and business partners should be aware of how data is handled and protected. Contracts should outline privacy expectations explicitly, with revisions during renewals to reflect changing laws and practices.
However, program awareness shouldn’t stop at training. Keep privacy top of mind through internal newsletters, team meetings, and leadership communications. A culture of privacy requires ongoing engagement and reinforcement.
Your organization’s privacy policies should be shared internally and with business partners. Training for internal stakeholders should be executed on a regular cadence. Privacy requirements for business partners should be explicitly communicated in your contract.
Contract renewals are a good time to review stated requirements for any amendments that may be required due to industry or legislative changes.
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There are serious consequences for organizations that fail to manage personal information ethically and securely. Regulatory penalties can be steep. Depending on the jurisdiction and severity of the violation, penalties can include millions of dollars in fines or a percentage of annual revenue. For example, Meta has been fined under GDPR (again) for a whopping $1.3 billion.
In addition to monetary fines, government orders may demand changes to business practices, suspend operations, or trigger in-depth audits. Privacy violations can also result in class-action lawsuits, long-term litigation costs, and increased insurance premiums.
Beyond the legal and financial toll, there are critical reputational and operational risks. Mishandled records—such as unauthorized access, improper disposal, or over-retention—can expose sensitive personal information. This can lead to client churn, eroded employee trust, and a damaged brand reputation. Ethical missteps may also reduce the confidence of potential partners or investors. Building an ethical, well-governed privacy program is the best safeguard against these outcomes.
A strong privacy program should include the following components:
Having a privacy program alone is not enough, though. Privacy topics and related policies should be regularly communicated in company newsletters and at group meetings. Leaders at all levels should reinforce reminders about why privacy protection is important and how individuals can support positive privacy outcomes.
Ethical privacy programs also embrace “privacy by design,” embedding protections into everyday workflows. This means that whenever possible, privacy principles should be built into operational processes that involve the collection, use, disclosure, protection, and retention of personal information. This practice enables employees to focus on their core business functions with confidence, knowing that privacy has been integrated into their everyday workflows.
Access’ Amanda Cavanah summarizes: “Key prevention through design strategies being employed by many organizations include collecting only data that is necessary, configuring systems for default security and privacy controls (rather than relying on user opt-in), enforcing the idea of least privileged access, and conducting regular audits to monitor the effectiveness of program controls.”
Ethical data handling protects against fines and lawsuits, but its true value lies in trust. Clients and employees are more likely to engage with organizations that show respect for personal data. Ethical privacy programs improve credibility, attract top talent, and reinforce your brand’s integrity.
Doing the right thing isn’t just a moral imperative. It’s a strategic advantage.
To learn how technology can help streamline and secure your records management processes while ensuring alignment with privacy regulations, watch the webinar recording of “The Tech Factor: Strategies for Effective Records Retention and Privacy.”
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