Interview with Charles Giordano
April 2003
Terry McQuay, President of Nymity, recently
spoke with Charles Giordano regarding Bell Canada's compliance
with PIPEDA.
Nymity: Charles, please provide background to privacy
at Bell Canada
Giordano: The current restrictions on confidentiality
of customer information were established with the Review of
the General Regulations of the Federally Regulated Terrestrial
Telecommunications Common Carriers, Telecom Decision CRTC
86-7, 26 March 1986. Each employee is reminded on an annual
basis of the rules & actions. We ensure all employees
sign a code of business conduct that requires the safeguarding
and proper use of personal customer information. We also place
strict controls on the protection and use of personal information
within our systems and web sites and ensure that our employees
are trained to respect your privacy at all times. We offer
a number of services to help balance the privacy interests
of customers and the people they call.
Nymity: What was your role at Bell regarding PIPEDA?
Giordano : During the compliance process I was appointed
project manager to implement PIPEDA on behalf of Bell &
affiliated companies. I engineered completion of privacy policy
& sign-off by the Bell companies. Also, the privacy team
developed a web interface for PIPEDA which included customer-friendly
opt-out capability.
Nymity: What are the privacy requirements as outlined by CRTC & Article 11?
Giordano: The major requirement is the restriction that prohibits
the provision of confidential customer information to third
parties without written customer consent.
Nymity: Please describe Bell's approach to compliance with PIPEDA
Giordano: We enhanced our current established privacy
practices & incorporated the specific PIPEDA recommendations.
The Bell Code of Fair Information Practices (the Code) complies
with the requirements of PIPEDA. We established an office
of the ombudsman, we sent all consumer customers a copy with
the bill insert. We added privacy policies to our web site
(bell.ca) & the front pages of our directories. Bell has
also undertaken a review of their information systems to ensure
that the provisions of the Privacy Codes will be adhered to.
Finally, regular internal audits will be employed to ensure
ongoing compliance.
Nymity: How did Bell approach employee education?
Giordano : Education has been a key to Bell's implementation
of PIPEDA. We started with a generic education program that
incorporated the key elements to the legislation & incorporated
the existing elements from our regulatory requirements under
Article 11. We then adapted the material for each business
unit, sales channel, and marketing group with the Bell family.
We targeted the customer-facing employees with face-to-face
training & then proceeded with marketing & rest of
the business units. An online internal course was developed
with mandatory participation on the do's & dont's in employee
privacy.
Nymity: Please describe the customer experiences, including sharing of information with Bell affiliates.
Giordano: Bell has a longstanding commitment to safeguard
privacy and it the reason for our reputation as a leader in
the protection of customer privacy. PIPEDA will enhance that
longstanding commitment. Consumers tend to view the Bell family
as a single entity. Consumers expect information to be shared
within these corporate groups, and indeed are surprised -
and in some cases, annoyed - where this is not the case. Bell
has a policy that no personal information will be disclosed
to unrelated third parties without the consent of the subscriber
in question. The web, directory & insert communication
ensured all our customers are informed of privacy at Bell.
Nymity: Please describe customer education that resulted because of PIPEDA.
Giordano : Bell's belief in privacy & protection of our
customer's personal information has resulted in few opt-outs.
The web, directory & insert communication ensured all
our customers are informed of privacy at Bell.
Nymity: What are Bell's current privacy challenges?
Giordano: To borrow the Ford Company slogan, building
quality in first. To embed privacy in all marketing &
IS/IT undertakings. To make privacy a positive as opposed
to reactive and only considering the negative consequences
of non-compliance. Keeping the customer data map current given
numerous channels, groups and sheer size of the Bell family.
Nymity: What was the most challenging aspect of compliance?
Giordano:
- Communicating privacy as a positive outcome
- Not having privacy add to the bureaucracy
- Constant communication & education given the size
of Bell
- Making privacy a value-add: can it actually bring in revenues?
Nymity: What recommendations would you make to our
subscriber about becoming compliant?
Giordano:
- Develop a team of key stakeholders
- Executive buy-in of importance of privacy
- Keeping up-to-date data map with ever-changing marketplace channels
- Network with privacy peers & "sponge" information
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