Privacy and Data Security

We have assisted clients on a wide range of privacy and data security compliance issues.  The following are some of the projects we have worked on:

• Serve as global privacy counsel to a Fortune 50 retailer. We assisted the client in developing a global privacy framework, including privacy governance documents, a vendor management program, data transfer documents and an information security program for emerging business initiatives. We also have initiated a project to map the company’s global data flows and determine program modifications and enhancements worldwide. In addition, we have drafted the company’s global privacy policy. 
• Regularly advise a Fortune 150 retail company on significant privacy and data security issues. We assisted the company with its data security breach remediation, including the development and implementation of a global comprehensive, written privacy and information security program. In addition, we have assisted the company with Payment Card Industry Data Security Standard (“PCI”) compliance activities and issues related to new payment card and loyalty card programs. We also have worked with the company to develop numerous privacy statements and notices (online and offline) worldwide and to manage privacy risks where vendors process personal data on behalf of the company. 
• Advising a Fortune 10 company on various U.S. and international privacy and data protection compliance initiatives, including assisting the company with its framework for the cross-border transfer of personal data to the United States. 
• Assist a Fortune 10 company with its privacy and data security needs, including developing its global privacy statements, as well as specific issues across 40 to 50 jurisdictions relating to consent requirements. We also advised the company on a variety of privacy and data security issues, including responding to global security breaches, preparing breach response procedures, advising on Red Flags Rule compliance, implementing an external instant messaging system and advising on employee monitoring. 
• Assisting a Fortune 500® financial services company with EU data protection compliance issues impacting the company, and also assisted the company in all aspects of its recent certification to the Safe Harbor framework. 
• Conducted an extensive privacy assessment for a Fortune 75 consumer goods company’s consumer marketing program. In connection with the assessment, we prepared data flow questionnaires, conducted interviews with employees and vendors, examined relevant documentation and prepared more than 60 data flow maps.