Privacy has become a critical business function. But companies go wrong when lawyers – rather than operations/IT and marketing personnel – take the lead. The nuts and bolts of privacy involve operational, technical and customer-engagement decisions – and it’s business leaders from these disciplines who must make and implement such decisions.

Zero-tolerance policies may sound good on paper, but there are endless examples of how zero-tolerance policies have been applied to absolutely absurd effect. Robert Zafft offers an alternative approach for corporate compliance programs – one that takes the focus off of severe penalties and instead stresses continuous improvement in processes and corporate culture.

Making an ethical business decision is often straightforward. What’s hard is implementing that decision throughout the organization while fending off attacks from reputational predators (activists, bloggers, journalists, etc.). Business leaders need to take four key steps to bolster their E&C efforts.