Writing Clear Policies and Procedures

Stop explaining privacy using privacy language. Please. Every time you mention "legitimate interest balancing tests" or "data protection by design principles," you are bound to lose the room. Almost no one you will encounter cares about the esoteric 7 principles of privacy by design. They care about not getting fired. Over and over I’ve watched privacy professionals present to their executive teams with dense slides, perfect regulatory citations and flawless legal reasoning. I was one of those professionals early in my career. Then questions like this emerge: "What does this mean for our Q4 launch?" Silence. Because we spent most of our energy on the compliance explanation and almost no energy on the business translation. Learning to do this takes time. It doesn't develop overnight. Here’s what can be effective: Instead of saying: "We need to implement proper consent mechanisms to comply with state privacy laws." Start saying: → "This will reduce spam complaints and improve your email deliverability rates." Instead of saying: "We need data minimization controls in scope." Start saying (to IT): → "This eliminates a manual process and reduces security exposure." Instead of saying: "We should respect data subject rights." Start saying (to Sales): → "This helps us avoid wasting time on prospects who are unlikely to convert anyway." You’re not hiding privacy requirements behind business benefits. You’re finding the genuine alignment between good privacy practices and outcomes they already care about. The Friction Reality: Most people who bypass privacy controls aren’t malicious. They’re busy. Under pressure. Measured on speed to market. If privacy means friction, they WILL find workarounds. I’ve seen this 100s of times and it’s not an attack on your work. It’s an invitation to build better systems. Real Talk: Your job isn’t to be the smartest person in the room about US Privacy Laws, GDPR or India’s DPDPA. Your job is to make privacy compliance as easy to understand as possible and efficient to implement so that people can’t accidentally get it wrong. What’s your best example of translating privacy into business language? Share below 👇

If your customers need a dictionary, a google search and a couple of phone calls to understand your process, we’ve got a problem. Leaders in regulated industries - like healthcare, banking, insurance and the others often sacrifice customer experiences at the altar of stringent compliance norms. Forms, procedures, and long processes become the standard. Jargons and tech talk get thrown around like confetti. Eventually it leaves customers feeling overwhelmed, frustrated, and helpless. When complexity becomes the default, customer relationships suffer. That's why we often see that as soon as a new entrant simplifies things, it triggers a big exodus of even loyal customers of existing brands towards the new option. Sometimes it happens quietly without a whimper. And as brand owners, if we end up noticing it too late, it hits growth, market share and profitability. Regulated industries can, and should create effortless customer experiences. Ease is not about bypassing compliance. It is about designing customer journeys that respect regulations while remaining: ✅ clear, ✅ empathetic, and ✅ straightforward. Here are THREE things I advise my clients who run a compliance-heavy business: 👉🏼 Make simplicity in communication non-negotiable. Replace jargon-filled language with clear, simple explanations. Start with the assumption that your customer does not understand a word of the compliances. The onus is always on you to make it easier to understand. 👉🏼 Proactivity goes a long way. Clarify expectations upfront. Explain the process upfront. Provide guidance and support upfront. This reduces customer effort, eliminates uncertainty and helps smooth sailing through compliance-related processes. 👉🏼 Infuse empathy into every interaction. Train teams to prioritize empathy. Train them on understanding customer perspectives and emotions. Train them to take ownership of the entire customer journey and not just a link in the chain. If you look at it now, these are three very simple things which I'm sure you already know in probably different contexts. But try applying it cohesively and consistently in the context of making your customer's life easy. That's when the magic happens! 🔮 P.S. Tag a company that went above and beyond to make a seemingly complicated task easy for you. Let's give them a shout out today! #CustomerExperience #CustomerDelight #Leadership #CustomerCentricity

Many years ago, I made a mistake that I see security leaders and security consultants repeat over and over again. I sent a beautifully written & crafted security policy to the executive team with a polite request for their approval. And then… crickets, nothing. Silence. Ghosted. No replies. At first, I thought, “They’re too busy.” But the reality was simpler... I gave them homework. I asked leaders who think in terms of growth, market share, and revenue to read 30 pages of controls and definitions. That was on me. The breakthrough came when I stopped asking them to read policies and instead asked them to own the intent of each policy. I boiled each policy down to its TLDR essence... one clear statement of leadership intent. I tied that intent directly to business goals, like revenue protection, operational resilience, customer trust. I framed the ask as consensus, not compliance... “Does this policy align with how we want to run the business?” Then I shared the resource requirements... the tools, headcount, and budget needed to make it real. Now, when I walk back in and say, “This tool satisfies these controls, which enforces this policy, which you agreed supports your business goals”… the budget discussion shifts. It’s no longer a security plea. It’s a business decision they’ve already committed to. Ok, so what's the lesson? Stop emailing policies. Stop giving executives homework. AND start having business conversations about intent, goals, and the resources to achieve them. #cybersecurity #policies #ciso #vciso #fciso

Never assume people are reading your policies the way you wrote them I once rolled out an updated data classification policy for an organization that handled regulated financial data. I had worked with legal and information security to make sure the policy was accurate, aligned with regulatory requirements, and covered all use cases. It defined four data categories, from public to restricted, with clear handling rules. I published it on the intranet, announced it through a company-wide email, and moved on. A few months later, during a routine vendor risk review, we found out that several departments had been emailing spreadsheets with confidential client data to third-party vendors without encryption. These files should have been labeled “restricted” under our policy, but no one had marked them, and no protections were in place. When we followed up, the response was the same across multiple teams. They had read the policy, but they had different interpretations of what qualified as restricted. One team thought it only applied to personally identifiable information. Another believed the rules only applied to formal reports, not ad hoc files. A few people admitted they were still using the old classification from a previous policy version. That incident created a serious risk exposure. We had to contact the vendors, implement new controls, and retrain multiple business units. We also had to report the issue to our internal risk committee. That experience taught me something I should have realized earlier. Publishing a policy is not the same as landing it. Just because something is written clearly to you does not mean it is clear to your audience. Now, every time I roll out a policy or a control, I schedule short walkthroughs with key stakeholder groups. I ask how they interpret the requirements, and I explain exactly how the policy maps to their work. I include examples that reflect real scenarios from their environment. I also check back a few weeks later to confirm the message stuck. The hardest part was realizing that my job was not just to write the right thing. It was to make sure people understood it, remembered it, and followed it. That change in mindset has made every policy more effective and every rollout more trusted. #GRC

After reviewing a handful of Privacy Notices at Hala Privacy, I can tell you what will REALLY make the difference: 1 - Be upfront about what data you are collecting. Make it clear from the start what data you are collecting and why. 2 - Focus on transparency, not legalese. People care most about how their data is used and protected. Avoid overwhelming them with long legal clauses upfront. Instead, start by addressing their concerns and explaining their rights in simple terms. 3 - Don’t overload with too much information at once. Keep the notice concise and to the point. Highlight what matters most, why you need their personal data, how you’ll protect it, and their control over it. 4 - Set clear expectations. Let people know how to access, correct, or delete their data. Provide a straightforward path to exercise their rights without navigating complex procedures.

Imagine two restaurants side by side. At first glance, they're identical – same menu, same decor, same staff. But peek behind the scenes, and you'll see a world of difference. Restaurant A runs like most. The waiter takes orders, the kitchen preps food, the maître d' manages ambiance, and the manager oversees operations. Each team works diligently, but in silos, with limited visibility into customer experiences beyond their immediate interactions. Now, Restaurant B? It's a whole different story. Here, every customer interaction is captured and instantly routed to the right team. A comment about the soup? The chef knows before the spoon hits the bowl. Feedback on the playlist? The maître d' is already queuing up the next track. But it goes deeper than that. In Restaurant B, the entire staff – from the dishwasher to the host – has access to customer feedback. This means everyone, not just the waitstaff, is in the business of retaining customers. The chef might tweak a recipe based on consistent feedback. The bartender could create a signature cocktail inspired by a regular's preference. The manager can proactively jump in to help when there is an issue. The result? A restaurant where every team member is attuned to customer needs, constantly adjusting and improving to keep diners coming back. Which restaurant do you think will do better? It's more than just collecting feedback – it's about systematically democratizing it across your entire organization. When every team has a direct line to the customer's voice, they're all empowered to contribute to retention. Are you running your business like Restaurant A or B? The choice might just determine your customer lifetime value. What steps are you taking to make the voice of the customer the driving force for every team in your organization? I'd love to hear your thoughts!

Step-by-step guide to help you embed privacy into the fabric of your products or services: 1. Establish a Privacy-Centric Culture:   - Integrate privacy into your company's mission, values, and overall strategy.   - Foster a culture of privacy awareness and responsibility throughout your organization.   - Appoint a dedicated Data Protection Officer (DPO) or privacy lead to oversee and champion privacy initiatives. 2. Conduct a Privacy Impact Assessment (PIA):   - Identify the types of personal data your product or service will collect, process, and store.   - Assess the potential privacy risks associated with your data processing activities.   - Evaluate the necessity and proportionality of the data collection and processing.   - Determine appropriate privacy controls and safeguards to mitigate risks. 3. Implement Privacy by Design:   - Embed privacy into the core functionality and architecture of your product or service from the ground up.   - Adopt data minimization principles and only collect and retain personal data that is strictly necessary.   - Implement pseudonymization and encryption techniques to protect sensitive data.   - Ensure that privacy controls are user-friendly and accessible to your customers. 4. Develop a Comprehensive Privacy Policy:   - Draft a clear, concise, and transparent privacy policy that explains your data practices.   - Describe the types of personal data collected, the purposes for which it is used, and how it is protected.   - Outline the individual's rights and choices regarding their personal data.   - Make it easily accessible and prominently displayed. 5. Obtain Valid Consent:   - Implement mechanisms to obtain explicit, informed, and freely given consent from individuals for data processing activities.   - Provide clear and specific information about the purposes for which data will be used.   - Offer granular consent options, allowing individuals to control their data preferences.   - Ensure that consent can be withdrawn easily and at any time. 6. Respect Data Subject Rights:   - Establish procedures to effectively handle data subject access requests.   - Implement processes to fulfill these requests in a timely and compliant manner.   - Maintain documentation and audit trails to demonstrate compliance. 7. Implement Security Measures:   - Adopt industry-standard security practices and technologies to protect personal data.   - Conduct regular security assessments and penetration testing to identify and mitigate vulnerabilities.   - Implement incident response and breach notification procedures to address and report security incidents promptly. 8. Transparency and Accountability:   - Maintain comprehensive records of your data processing activities.   - Conduct regular privacy audits and assessments to ensure ongoing compliance.   9. Stay Up-to-Date with Regulations:   - Monitor and adapt to evolving privacy laws and regulations, such as GDPR, CCPA or DPDPA.   

What steps taken to arrest tendency huge complaints from the customers against the institution staff and top management behavior? 1. Diagnose the Root Causes Conduct an Internal Audit: Review past complaints to identify recurring patterns related to behavior. Analyze Feedback Channels: Use surveys, focus groups, or direct interviews with customers to understand their grievances. Employee Feedback: Encourage staff to share internal challenges that might impact their behavior. 2. Strengthen Employee Training Customer Service Training: Regularly train employees in empathy, communication skills, and conflict resolution. Cultural Sensitivity: If complaints involve biases or cultural misunderstandings, prioritize diversity and inclusion training. 3. Enforce a Code of Conduct Define Standards: Develop and communicate clear behavior expectations for all employees, from entry-level to top management. Zero Tolerance Policy: Establish strict consequences for behaviors that violate customer respect or ethical standards. 4. Foster a Customer-Centric Culture Empathy-Driven Policies: Encourage staff to view situations from the customer’s perspective and prioritize solutions over defensiveness. Recognition Programs: Reward employees who demonstrate outstanding customer service and behavior. 5. Improve Complaint Handling Processes Streamline Reporting: Make it easy for customers to register complaints through multiple channels (phone, email, online forms). Quick Resolutions: Address complaints promptly with clear communication on the resolution timeline. Empower Frontline Staff: Allow employees to resolve issues at the first point of contact to minimize escalation. 6. Introduce Regular Feedback Mechanisms Customer Satisfaction Surveys (CSAT): Continuously monitor customer perceptions. Internal Feedback Loop: Share trends and actionable insights from customer feedback with all levels of staff and management. 7. Address Leadership Accountability Leadership Example: Ensure top management sets the tone for respectful and professional interactions. Behavioral KPIs: Include customer satisfaction metrics in performance evaluations for staff and management. 8. Engage in Conflict Resolution Mediation Programs: Introduce trained mediators to resolve conflicts between customers and staff professionally. Escalation Framework: Clearly define escalation paths for unresolved complaints to ensure management accountability. 9. Implement Technology Solutions CRM Systems: Use customer relationship management tools to track complaints, responses, and resolutions efficiently. Behavior Analytics: Monitor behavioral patterns through feedback systems and employee performance data. 10. Monitor Progress and Adapt Regular Audits: Periodically assess complaint resolution effectiveness and employee behavior improvements. Continuous Learning: Adjust training and policies based on evolving customer needs and industry benchmarks.

Guests Don’t Just Wait in Queues. They Feel Them. Every restaurant faces queues and wait times, whether it’s a Friday night in Riyadh, a brunch in Dubai, or a family dinner rush in Kuwait. But here’s the truth: guests don’t measure the actual wait. They measure how the wait feels. A 15-minute wait with no communication feels like an eternity. A 25-minute wait with transparency, comfort, and small gestures can feel reasonable. That’s the psychology of queues. Why it matters in the GCC: In markets where guests hae endless alternatives, poor wait experiences don’t just lose a table, they can lose loyalty forever. Families, especially, are unlikely to return if children are left restless or ignored in the first visit. What smart operators do: 1. Set expectations early In Doha, one fine dining brand tells guests the estimated wait time at arrival. Guests appreciate honesty and are less frustrated if the time matches reality. 2. Make waiting active, not passive In Dubai, a café offers digital menus and water immediately to waiting guests. It changes the mindset from “I’m wasting time” to “my experience has already started.” 3. Use the environment Comfortable seating, lighting, and music reduce perceived wait times. A casual dining group in Kuwait transformed a dull waiting area into a lounge-style corner and saw higher guest patience during peak hours. 4. Small gestures go a long way Free samples, a warm greeting, or entertainment for children. In KSA, a family dining brand hands balloons to kids waiting. Parents remember that far more than the delay. Best practice examples from the GCC: • A Dubai QSR introduced real-time queue screens showing order status. Transparency reduced complaints, even when waits were long. • In Riyadh, a premium restaurant texts guests when their table is ready, allowing them to explore the mall instead of standing in line. • A Kuwaiti casual brand hands out tasters of their signature appetiser to those waiting on weekends. Guests leave happier, and sales of that dish rise once they’re seated. The lesson: guests rarely forgive long waits, but they often forgive well-managed waits. Because in hospitality, it’s not just about the minutes they wait, it’s about the memory of how you treated them while they waited. #Hospitality #GuestExperience #CustomerService #GCCRestaurants #FandB #HospitalityLeadership #KuwaitRestaurants #DubaiRestaurants #QatarRestaurants #KSAHospitality #Gastronomica

What is wrong with your privacy notices? What can companies in the US and EU learn from the new Datu valsts inspekcija/Data State Inspectorate of Latvia guidance issued based on its inspections: 🔹Put the notice somewhere it is easy to find and access 🔹Do not include it under "Terms of Use" or "For customer" 🔹Put a separate privacy notice link which is called something obvious like "Privacy Notice/Policy". Don't just include the link inside your cookie settings interface. 🔹Do NOT copy another website's notice or use a standardized one without modification. 🔹Only provide information that is relevant to your own actual processing. 🔹Give the notice a clear logical structure; with sections and without unnecessary repetitions. 🔹Ensure that it is easily understood by people without prior knowledge of personal data processing regulations. 🔹Make sure to include all your processing purposes 🔹You must provide the information in a way that clearly identifies the legal basis for each processing operation, describing it in a concise manner, leaving no room for interpretation which legal basis applies to which purpose. 🔹Therefore, it would not be correct to indicate the purposes and legal basis for data processing in separate sections of the privacy policy without linking them, as we have observed in the privacy policies of various organization 🔹If relying on legitimate interest: You must specify for which specific legitimate interests the data is processed. 🔹Saying "data will be processed for as long as necessary to achieve the purposes of the processing.” is too general. You must provide a timeframe for how long the data will be stored (in months, days, years), or, if this is not possible, as specific as possible as to the criteria used to determine that timeframe, tailored to the specific category of data and the purposes of the processing. 🔹You need to list specific recipients. If for some reason it cannot be published publicly, indicating their categories (e.g. recipients of delivery services, providers of accounting services, etc.). 🔹You need to list the rights and how to exercise then and that has to be a manner which is convenient and accessible. #privacyFOMO pic by ChatGPT https://lnkd.in/ejJuV7rm