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Ethical Data Handling Strategy

ComponentDescription
Values statementsValues statements describe what the organizations believe in. Examples might include truth, fairness, or justice. These statements provide a framework for ethical handling of data and decision-making.
Ethical data handling principlesEthical data handling principles describe how an organization approaches challenges presented by data; for example, how to respect the right of individuals to privacy. Principles and expected behaviors can be summarized in a code of ethics and supported through an ethics policy. Socialization of the code and policy should be included in the training and communications plan.
Compliance frameworkA compliance framework includes factors that drive organizational obligations. Ethical behaviors should enable the organization to meet compliance requirements. Compliance requirements are influenced by geographic and sector concerns.
Risk assessmentsRisk assessments identify the likelihood and the implications of specific problems arising within the organization. These should be used to prioritize actions related to mitigation, including employee compliance with ethical principles.
Training and communicationsTraining should include review of the code of ethics. Employee must sign off that they are familiar with the code and the implications of unethical handling of data. Training needs to be ongoing, for example, through a requirement for an annual ethics statement affirmation. Communications should reach all employees.
RoadmapThe roadmap should include a timeline with activities that can be approved by management. Activities will include execution of the training and communications plan, identification, and remediation of gaps in existing practices, risk mitigation, and monitoring plans. Develop detailed statements that reflect the target position of the organization on the appropriate handling of data, include roles, responsibilities, and processes, and references to experts for more information. The roadmap should cover all applicable laws, and cultural factors.
Approach to auditing and monitoringEthical ideas and the code of ethics can be reinforced through training. It is also advisable to monitor specific activities to ensure that they are being executed in compliance with ethical principles.

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