Our customers entrust us with their personal information and the confidentiality of their private communications. The way we handle this information is a vital part of our responsibility to customers and how we earn their trust.
Group Privacy Policy
Our Group-wide Privacy Policy covers the collection, storage and use of our customers’ personal information. The policy must be implemented by every Vodafone local operating company and is overseen by our Content and Privacy Steering Group, a cross-functional body made up of senior management.
Privacy officers with day-to-day responsibility for compliance with the policy must be appointed by all our operating companies. These local privacy officers and privacy experts participate in a regular meeting led by our Group privacy officer.
A dedicated privacy wiki and blog on our intranet is designed to raise awareness among our employees about our approach to privacy from a legal, ethical and social perspective by providing information on topical issues, and how they affect Vodafone and our customers.
Vodafone also has a dedicated advisor within the Group Fraud, Risk and Security function to advise on and coordinate the assistance provided by our local Fraud, Risk and Security teams to law enforcement authorities.
Data security
Keeping personal information safe is the most basic responsibility entrusted to organisations. Any breaches of data security could have a devastating impact on our business. To prevent this, we have implemented state-of-the-art security measures and technologies across the Group, conducted awareness-raising initiatives among employees and established a robust legal model to ensure that our security controls cover external partners with access to Vodafone data.
Human rights, privacy and freedom of expression
Telecommunications operators, including Vodafone, have traditionally been required to support law enforcement authorities by disclosing certain information on users and providing assistance with real time surveillance in the fight against serious crime and terrorism. These demands have increased in recent years with heightened concerns about terrorism. While this support and assistance plays an essential role in the protection of public safety and security, we must remain vigilant to ensure that this is done lawfully and does not unnecessarily interfere with the privacy of our customers.
We were closely involved in the multi-stakeholder dialogue to create the Global Network Initiative (GNI) principles, which recognise that ICT companies have a responsibility to respect and protect the freedom of expression and privacy rights of their users. However, Vodafone has decided not to sign up to the GNI principles because their current focus is on issues primarily affecting internet providers. There are substantial operational and regulatory differences between internet and telecommunications companies, which operate under licence from national authorities in each jurisdiction.
We will continue to engage with the initiative and with other telecommunications companies to build on this progress and establish common principles. This engagement is also helping to inform the development of Vodafone’s own policy on assisting law enforcement assistance to ensure we strike the right balance between the potentially conflicting obligations of safeguarding privacy and assisting law enforcement.
Social networking and social media
Social networking and social media sites have created new ways to communicate and share information. The amount of personal information generated is vast and remains in the public domain once published. This raises the issue of information being seen by unintended audiences (eg. an employer seeing an embarrassing photo intended to be shared with friends), potential for identity theft and concerns about children’s use of these services (see content standards).
Vodafone has agreements with several social networking sites to offer their services over our network, and we also have our own wireless address book service, ZYB. We need to identify potential privacy risks and ensure that our users are informed and understand these risks. Vodafone has developed design principles for social networking services and social media that take this into account, and we have signed up to the EU Guidelines on safe social networking.
