Building a Privacy by Design Program for a Regional Hospitality Leader
Case Study
Client Overview
A “Regional Accommodation Provider” * secured a high-profile contract with a multinational company placing its employees in accommodations worldwide. This contract required the provider to collect, manage, and protect sensitive personal data, including passports, nationalities, and other employee information. However, the Provider lacked a formal privacy program to meet the stringent contract requirements.
Recognizing the urgency, the Provider engaged Ethos to design and implement a phased Privacy by Design program tailored to meet their immediate needs while building a sustainable foundation for long-term compliance.
* Not the client’s real name. All identifying details have been changed to protect client confidentiality.
Challenges
- Very limited privacy framework, policies, or processes in place.
- Immediate need to comply with contractual requirements and global regulations.
- Handling of sensitive personal data required secure processes for collection, retention, use, disclosure, and disposal.
- Tight implementation timeline to fulfill contractual obligations.
Our Approach
Leveraging our proven Privacy by Design methodology, we conducted a comprehensive assessment of PackCo Solutions’ data handling practices & developed a tailored integration roadmap that aligned with Global Distributors’ privacy framework while ensuring compliance with GDPR & CCPA regulations.
- Conducted a Privacy Risk Assessment to identify the most urgent risks in handling sensitive personal data.
- Implemented core privacy policies and procedures to address critical contractual requirements for data collection, retention, and disclosure.
- Developed and deployed a Privacy Notice to ensure transparency with data subjects.
- Established encryption and secure access controls for sensitive data to mitigate immediate risks.
- Retention and Disposal Framework: Introduced automated data retention schedules and secure disposal procedures to ensure compliance with data minimization principles.
- Employee Training: Delivered foundational training to ensure staff could immediately begin implementing privacy practices, followed by advanced role-specific training sessions.
- Client Reporting Tools: Integrated systems for seamless communication and reporting to their clients regarding privacy compliance.
- Designed a Privacy by Design Framework to embed privacy considerations into all operations, ensuring future projects aligned with compliance requirements.
- Set up an ongoing Audit and Monitoring Program to address evolving privacy regulations and maintain compliance.
- Successfully implemented a comprehensive third-party risk management framework for our client, significantly enhancing their supply chain data privacy protection.
- Established a dedicated Privacy Officer role to oversee long-term implementation and adaptation.
Results
Immediate Compliance Achieved
Provider met critical privacy requirements within the contract timeline, satisfying their client and preventing operational delays.
Scalable Solutions
Progressively implemented additional privacy services as resources allowed, creating a robust and adaptable privacy program.
Risk Mitigation
Reduced the risk of data breaches and regulatory penalties through secure data handling practices
Client Trust Strengthened
Demonstrated a commitment to privacy and security, cementing a strong partnership with their clients.
Client Testimonial
