Privacy Policies of Zuger Law Office, PLLC
This section of the Course Paper, which may be named whatever you like (e.g., “Executive Summary,” “Introduction,” “Preamble,” etc.), should only be a handful of sentences; certainly no more than a page. Here, your team will describe the nature of your business. You should explain what your firm does, who your customers are, and briefly mention any other key stakeholders in light of privacy concerns. This is also the place to list your team members. And, finally, in this section, you should explain to your audience—i.e., your company’s staff—why privacy is important in your business. Essentially, this is where you “sell” your audience on the fact that they must abide by your company’s privacy policies.
The contents of these policies should contain at least the following features:
· The policy, itself, such as “Reasonable Expectation of Privacy for Employees.”
· The laws, regulations, or standards that relate to the policy at issue.
· An example, when applicable, that helps your audience understand the policy.
· Directions on how to effect the policy. For example, if your company processes payments by credit or debit cards, and your policy is something like “Anyone who processes payments via payment cards must conform their actions to PCI DSS standards related to privacy.” then you may want to insert a link to those standards. Or, perhaps, incorporate examples as mentioned directly above.
This list is not exhaustive. Depending on the set of facts, you may need to include more.
The Policy Statements must be a comprehensive body. Do not omit the discussion of laws that may apply to your business. This means that you must understand what your business does, and its privacy implications. Every company has employees, so employees’ privacy must be addressed. While it is debatable, I have discussed that any HRIS, or a company’s personnel records kept otherwise, has the propensity to contain medical information that we now know to refer to as “PHI.” Thus, you should have some policy that governs handling those data vis-à-vis privacy. Could your company be known as a “financial institution?” If so, you must discuss GLB Act privacy policies.
The point is that in three to five pages you must tell your employees everything they need to know about maintaining appropriate privacy while conducting your business.
The Course Paper is worth 100 points. I will give up to ten points for the submission’s form and format. That includes its organization, page count and team size, and grammar and spelling. The form and format is important because if a policy document is disorganized, contains typographical errors, or is hard to read otherwise, employees will not respect or even use it as the guidance it is meant to be. Consider a numbering or another outline styled structure to identify policy clauses.
I will give up to ten additional points for the introductory section, and whether you included all of the required information.
I will give up to 80 points for the policy statements. Questions I will have in mind when reviewing your policy statements include, Did the team incorporate what we’ve learned about privacy? Can the document be read and understood by all levels of an organization? Are the policies concise, or vague and wordy?
Writing assistance is available by emailing a copy of your file to the International Academic Services office (yes, even if you are not an international student) at [email protected]. I highly recommend that you give the IAS Team at least two or three business days to review your work. Take into consideration the fact that you will likely need to respond to their efforts with some rewriting of your own, and you can start to calculate how much in advance of April 23 you should be planning on sending them a draft.
Here are some of the ways that students have lost points in prior years:
· Teams and pages. Do not submit as an individual; you must be part of a team. Do not exceed the page count. Only use Microsoft Word (.doc or .docx) or Adobe PDF format. Each team member must individually submit a copy of the team’s work. You cannot rely on one member’s submission. And, when two team members submit dissimilar work, it evinces a non-functioning team.
· Don’t skip the obvious. If you are an insurance company, and fail to draft a policy that addresses HIPAA privacy, that’s a big omission. If children may access your website, you better include some acknowledgement of COPPA and CIPA’s privacy laws. See, Policy 1.3, above.
· Get going now. While having up to five people working on this can make it very easy to accomplish, you cannot wait until the end of the course to start.
· Perfect the writing. Spelling errors, syntax and grammar issues, and other poor English writing artifacts all take away from the credibility of your policies. When your company does not care enough to write well, your employees will not care enough about privacy to help you avoid risks.
· This is a policy document. In some prior examples, valuable paper “real estate” was wasted on describing marketing plans, or a company’s history, or other immaterial data. The introductory section is important, but it is not the crux of this learning objective.
There are other ways that students have lost points, so please consider the entire body of instructions and requirements. These, in my opinion, came up often enough, or were easy enough to avoid, to include for your benefit.
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