It is important for businesses to develop clear internal policies specifying the types and intended use of consumer data collected. Companies must understand that indiscriminate data collection (i.e. collecting customer information with no immediately identifiable business purpose) can be problematic and could unnecessarily create potential liability in the event of a data breach, with no offsetting organizational benefit. Also, businesses that collect data from a myriad of sources subject to a wide range of use restrictions must tread lightly given the difficulty in identifying how such information can be utilized.
M&R’s Privacy Team counsels clients on how to align data collection and disclosure practices with current and future business plans. At the same time, the firm provides advice and counsel regarding risk assessment, management, and strategies to (1) expand potential uses for collected data and (2) open up actual or pseudonymous data sets for use in analytics, monetization, or other purposes.