In the digital age, where data crosses borders with ease, ensuring the privacy and security of sensitive information is paramount for organizations operating on a global scale. The challenge intensifies with remote and distributed teams, where workers operate across regions with varying personal data protection regulations.
Deel, a leader in global workforce management, has navigated these complexities by developing a robust framework for global privacy compliance, offering valuable insights and principles for organizations aiming to safeguard their data worldwide.
💡 Looking to create your own privacy policy for your global business? Download our free global data privacy policy template now.
Global privacy policy best practices
The first step in developing robust data privacy and protection measures is implementing a global privacy or data protection policy to provide clear and easily accessible information about how your organization collects, uses, stores, shares, and protects personal data globally.
A global privacy policy can apply to anyone who interacts with your organization: Website visitors, app users, customers, employees, contractors, and anyone else who provides personal information. It's essential to building user trust and understanding, as it gives users transparency about what happens to their data.
Deel’s privacy policy follows a typical framework but includes special clauses and language to ensure compliance with all international data privacy and protection laws and regulations. Here's a step-by-step summary of how it works:
Accommodate the strictest requirements
Your privacy policy must apply to all data privacy laws in every jurisdiction where your company operates and processes personal data. Since this is a complex task for multinational companies, the best approach is to design your policy to accommodate the strictest country requirements.
For instance, several regions have implemented strong data privacy regulations granting individuals significant rights over their personal information. By granting all data subjects the same rights, you can adhere to the highest global standards no matter which laws or regulations apply.
Europe’s General Data Protection Regulation (GDPR) is often considered one of the strictest data protection regulations globally due to its comprehensive scope, stringent requirements, and the significant fines it can impose for non-compliance.
In many cases, Deel's policy applies the GDPR requirements but keeps the language general, communicating that the policy offers the same high standards of privacy protection regardless of where users are in the world.
For example:
Link out to DPA’s where possible
An important aspect of a global privacy policy is explaining how user data is processed. To keep your policy concise for user clarity and adaptability across regions, you should refrain from including detailed explanations of data processing practices and instead link out to data processing addendums (DPAs).
DPAs are legally binding contracts that clarify the roles and responsibilities between data controllers (your company) and processors (entities that process personal data on behalf of a data controller under specific instructions) and include details on the controls for access, data retention, and minimization, breach notification, and incident response procedures.
DPAs are crucial components to reference in global privacy policies since they help manage the complexities of cross-border data transfers through mechanisms like standard contractual clauses (SCCs), which ensure adequate protection of personal data when transferred outside of its original jurisdiction.
Deel's DPA defines key terms and acknowledges the global landscape of data protection laws, including specific mentions of EU/UK and non-EU data protection laws. This approach ensures broad coverage and applicability across different jurisdictions.
Include an international transfer section
It's common practice for companies that operate globally to transfer personal data across international borders and jurisdictions, whether to your company's headquarters or other international subsidiaries, affiliates, and business partners with whom your business interacts.
It’s important to acknowledge international data transfers within your global privacy policy so that users know that by using your product or service, they have given permission for this data transfer and that safeguards remain in place to keep their personal information protected regardless of any differing laws.
Deel’s global privacy policy includes an international transfer section to explain the operational need for such transfers, which might include processing payroll, providing customer support, data storage, and other essential services that require data to be accessed from different locations worldwide.
For example:
Include region-specific privacy terms
Users from regions with strict or complex privacy laws might be more sensitive about their data privacy. Addressing these concerns directly in your policy can alleviate their worries and reassure them that their data is protected to the highest standards.
For example, unlike the European Union, the United Kingdom, and Switzerland, which the GDPR covers, the United States relies on a patchwork of federal and state-level laws governing data privacy and protection. Highlighting the unique features under each state law empowers users to understand their data privacy rights and seek accountability from businesses operating in their state.
Here are a few countries and US states with notable data privacy laws and regulations that Deel references in its global privacy policy:
- China: China's approach to data privacy differs significantly from GDPR and other Western frameworks, prioritizing national security and social stability alongside individual rights
- Brazil: Brazil has recently gained recognition for its notable data privacy and protection laws, primarily due to the implementation of its General Data Protection Law (LGPD) in 2020
- California: California's notable stance on data privacy legislation, particularly through the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA), stems from its pioneering efforts to address the growing concerns over personal data privacy and security in the digital age
Building out a NDA agreement? Get our free template that we've annotated with notes tailored for remote and international teams.
Global data protection measures
Once you have a global privacy policy in place, it can serve as your North Star, guiding your privacy procedures and processes. Below, we share some of Deel's data protection processes and measures and how you can apply them to your organization.
Centralize your data processing activities
Many global companies, including Deel, centralize their data processing activities to streamline operations, maintain consistency in data handling practices, and ensure comprehensive data security measures.
Centralizing data processing at your company headquarters allows you to leverage economies of scale and utilize the same sophisticated data management and protection measures that might be difficult to replicate across multiple locations.
Implement an incident response plan
Having a formal procedure for handling personal data breaches is essential. Deel has dedicated response plans for various incidents, including virus security breaches, personal data breaches, distributed denial of service, unauthorized use of an employee's credentials, cybersecurity attacks, and general security incidents.
Use sophisticated data storage, encryption, and backup methods
Hosting your company's production data on a cloud computing platform that prioritizes security with DDoS protection and Key Management Service (KMS) ensures that only authorized users can access sensitive data and cyber attacks are detected and mitigated.
Deel hosts its production data in Amazon Web Services (AWS), and it's backed up and encrypted daily. All data at rest is encrypted using AES-256, and all data in transit is encrypted using TLS 1.2, state-of-the-art encryption methods.
Implement data registries
Implementing data registries, such as a personal data processing registry, a data breach registry, and a data subject request registry, helps to systematically document these activities, breaches, and requests from data subjects, ensuring compliance with legal obligations and avoiding potential fines.
Deel has implemented several organizational measures to protect data, including a personal data processing registry, a data breach registry, and a data subject request registry.
Implement access control
Your company should use access control measures to ensure that only authorized users or applications can access specific functionalities or data, protecting against unauthorized use of sensitive information.
Deel manages access control through JumpCloud, a trusted directory platform that authenticates, authorizes, and manages users, devices, and applications.
Obtain compliance certifications
Your company should work towards obtaining compliance certifications from respected bodies to ensure regulatory compliance and operational efficiency and enhance trust among customers, partners, and the broader industry ecosystem.
Deel has ISO27001 and SOC2 certifications, which are updated regularly. These certifications demonstrate Deel’s commitment to maintaining high standards of data security. Deel is also certified under the EU-US Privacy Framework, ensuring safe data transfer from the EU and UK to the US.
Sign confidentiality agreements and NDAs
Creating and signing confidentiality agreements and non-disclosure agreements with employees and contractors who handle your sensitive user data is essential for safeguarding the company’s interests, ensuring compliance with data protection laws, mitigating risks, and upholding the trust and confidence of customers, investors, and partners.
Deel advises clients to sign confidentiality and non-disclosure agreements with employees who handle international data. These agreements prohibit the employee from disclosing or using personal data for unauthorized purposes, thereby ensuring the protection and confidentiality of personal data accessed during their work.
Protect data privacy globally with Deel
When you hire international employees and contractors through Deel, you and your global hires benefit from all the global data privacy and compliance protections, policies, and procedures Deel has designed.
Here's what's included:
- Data privacy policy: Deel's global privacy policy provides information about how different types of data are collected, used, and disclosed when clients access Deel's site and services. This policy is updated regularly to ensure it remains compliant with global data privacy standards
- Data processing addendums (DPA): Deel offers a comprehensive, global DPA to meet the requirements for GDPR and beyond. The DPA regulates several aspects of the data processing of two parties, including the purposes of processing, the parties' relationship, data transfer safeguards, the categories of personal data being processed, and a list of Deel's sub-processors
- Data subject rights: In data protection law, data subjects (employees or contractors hired through Deel) may exercise several rights toward the party processing their personal data. These rights include the right to be informed, the right to access, the right to erasure, the right to object, and the right to portability between organizations. Deel has a data subject rights management procedure in place to ensure these rights are respected
- Data breach procedure: Deel has procedures for handling potential data breaches. This includes measures to prevent unauthorized access to or disclosure of personal data
- Continuous compliance: Compliance is a core part of Deel's infrastructure. As a global provider, Deel deeply understands the legal and regulatory requirements of operating in different jurisdictions and has designed its services to ensure continuous compliance with these requirements
- Expert team: Deel has a team of in-house legal experts and compliance managers specializing in data protection and privacy. This team includes privacy specialists, lawyers, and IT specialists
- Incident response: In case of any data breaches or incidents, the team assists in responding to these incidents
- External partners: Deel also has a broad network of 200+ legal partners worldwide, which further strengthens its ability to stay updated with global legal and regulatory changes
Sounds like the solution you're looking for? Book a demo today to streamline global data protection for your company.
