Marc Mandel spent hours poring over a task for his new privacy service. It involved a key detail most probably do not have on their mind when launching a new product. He was looking for the right phone number.
Finding a phone number is unlikely to be at the top of anyone's to-do list, but for Mandel, it was a key piece to what he and his team were trying to launch.
Mandel is the co-founder of Privacy Toll Free, a platform that recently launched the CCPA Toll Free service. Organizations can sign up to provide a resource for data subjects to express their privacy preferences through a toll-free phone number.
The tool was developed as a response to the provision within the California Consumer Privacy Act that requires organizations to set up and maintain a toll-free number. (DLA Piper Partner Jim Halpert writes about amendments that created exemptions for this requirement in this piece for Privacy Tracker.)
Consumers can call the number and enter the code in order to exercise their data rights under the CCPA. What they hear when they call will be up to the company, Mandel said. Organizations will have access to a dashboard where they can customize the greeting data subjects will listen to. Should they choose the default greeting, consumers will hear a rundown of their basic CCPA data rights and go from there.
“I have a feeling a lot privacy practitioners or consultants may end up helping people with this,” said Mandel. “Maybe helping to design the right greeting if they want to use a customized one, but if you are just a business owner who wants to get set up, it’s designed to be able to do it quickly.”
After individuals make their request, the inquiry is sent to the same dashboard in order for it to be fulfilled. Once it is completed, companies can either confirm it via email or phone. Mandel said the dashboard has a compliance-tracker feature, which allows companies to take notes about each request and provides an audit trail for compliance purposes. In the event a company decides it needs to extend a request under the CCPA’s 45-day limit, the dashboard will automatically recalculate the due date for the action.
As for who is answering these responses, Mandel said it will depend on the organization. For larger entities, these requests may end up crossing departments.
“I think that this sits somewhere between legal and customer care in the business organization. It depends on the size of the organization and the nature of the request,” said Mandel. “In a larger organization, I would imagine both the legal department and the customer care department would have access to the dashboard and presumably legal would set up some guardrails around how to respond to typical requests and if anything is atypical, that might get routed through to legal.”
In an age when most privacy solutions exist almost exclusively online, it may seem like a shock to the system to see a service centered around the telephone. Mandel does not see it this way, however, as he has seen ten proposed privacy bills where toll-free numbers are either required or recommended.
Mandel said privacy legislation beyond the CCPA will eventually cover individuals who live in rural areas where internet access is suboptimal, which means phone services are still a crucial method for those who wish to have their privacy rights respected.
“I think the telephone isn’t going away any time soon. There are hosts of businesses that are continuing to offer telephone support and there are people who prefer to reach out and talk to someone, and the statutes are recognizing that,” said Mandel. “Because consumer privacy is so important, they are now legislating that you should be offering that type interaction with your consumers when it comes to their privacy choices.”
After he first spotted the CCPA provision on toll-free numbers, Mandel felt it was an area where he could make a positive impact on the privacy community. He cites this foresight, as well as his “lean team,” as the reasons why he was able to get a head start on the market for privacy-focused toll-free numbers. As more privacy laws featuring similar provisions go into effect, Mandel does not expect his service to be the only one, as demand will likely bring out competitors.
For now, Mandel and his team will keep their eyes out for those laws, while looking for ways to enhance their existing offering. Mandel said his team may look to further automate requests through the touch tone system for companies that may have phone numbers already on file.
Mandel believes privacy hotlines are coming into prominence, and if that is the case, no one will want to be stuck with the wrong number.
Photo courtesy of Marc Mandel.
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