Company Updates

Transparency – The Critical Trust Enabler

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Various consumer privacy laws (such as GDPR and the California Consumer Privacy Act) recognizes transparency as a core principle of data protection.  Simply stated, transparency is related to the fair processing principle and processing can only be fair if it takes place in a transparent manner.

However, transparency is only relevant if it is meaningful.  In practice, this means that a business will need to clearly communicate to their users about their data collection practice, which is usually in the form of a privacy statement. The privacy statement cannot be “overly legalistic, technical or use specialist language or terminology” as highlighted by the Article 29 Data Protection Working Party.  In other words, by adopting the “K.I.S.S.” principle (which has been associated with the aircraft engineer Kelly Johnson), which is, “keep it simple and straightforward”, users will likely entrust you with their personal data.

So how can a business achieve user-centric transparency? By focusing on sharing meaningful information in clear, concise and plain language to truly inform users about how their personal data will be used, collected and shared throughout the lifecycle of the user’s data.

Furthermore, transparency should be context-specific, flexible, dynamic and adaptable to enable a genuine choice to users.  By embracing this approach, it builds user trust and digital confidence as well as deepens the regulator’s trust.

At Dell Technologies, transparency is an enduring commitment and our 2030 privacy moonshot goals are focused on putting our customers’ and employees’ in the driver’s seat in how they control their personal data by:

  1. Continuing to provide user-centric and transparent privacy statement;
  2. Leveraging leading-edge technology to make it easier for our customers to access or delete their personal information and to exercise their choices; and
  3. Championing our customers’ and employees’ privacy rights by helping shape new consumer privacy laws with their rights in mind.

Dell’s pledge of transparency sets a solid foundation for evolving technologies and embedding digital confidence.

Last but not least, Dell Technologies will continue to invest in our advanced and comprehensive RSA Archer privacy governance and risk management technology to protect the personal data you entrust us with.

About the Author: Sooji Seo

Sooji Seo joined Dell in 2007 as legal counsel for Dell’s Australia and New Zealand business. During her tenure at Dell, Sooji has held various leadership roles in privacy, regulatory compliance and strategic legal advisory support. Sooji currently serves as Vice President and Chief Privacy Officer, which provides a broad range of leadership involving direct support and execution for the design, development, coordination, implementation and ongoing management of Dell’s global privacy program across Dell's global enterprise. This position leads a global team of privacy attorneys and certified privacy compliance professionals who are responsible to build, implement and manage a best-in-class and standardized global privacy program, in a highly regulated global environment. Prior to joining Dell, Sooji was General Counsel for Hunter Douglas Limited and Chubb Australasia. Sooji has over 20 years of legal advisory, compliance risk management and risk governance, regulatory enforcement and commercial litigation experience. Sooji is also a regular speaker at compliance seminars and conferences in the United States and the Asia Pacific region. Sooji received her Bachelor of Laws (Honors) from the University of Technology, Sydney and a Bachelor of Computing Science and Mathematics from the University of New South Wales. She is a member of the New South Wales (Australian) Bar Association, the Singapore Corporate Counsel Association and the American Association of Corporate Counsel.