When privacy officers and organizations do trip up on international laws, she says, the stumble is over one of two obstacles: cultural differences in individual markets, or getting lost in the details of each market's unique laws.
One key to overcoming those obstacles: "You have to have the senior leaders in your organization say that privacy compliance is important, and make that part of the corporate culture," says Wugmeister, an attorney in the New York office of the Morrison & Foerster LLP law firm.
Wugmeister's advice to leaders: Focus on the common elements."There is a great deal in common among the different laws," she says. "Most of these privacy laws around the world have some very similar, common principles. They all require that you give notice to individuals; they all require that you keep data secure. The goal is to figure out what are those common elements."
In an interview about managing global privacy legislation trends, Wugmeister discusses:
Wugmeister is chair of the firm's global privacy and data security group. She counsels clients regarding the collection, use, disclosure and transfer of personal information as organizations seek to comply with U.S. and international data protection laws. Wugmeister has advised dozens of global companies on multinational compliance efforts, including the consolidation of human resources and customer data into a single database; global technology use and monitoring policies and procedures; handling of personal information in the context of sourcing transactions; global data security standards; e-discovery and international privacy issues; the implications of various local and national laws on direct marketing initiatives; and security breach notification policies and responses.
Wugmeister also leads the Global Privacy Alliance, which encourages the rational development of privacy laws around the world and monitors privacy practices, laws and regulations globally.