Category Archives: Reputation Risk

Human Trafficking and Supply Chains: Q&A with Tim Nelson of the Slave-Free Alliance

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The International Labour Organization estimates that 25 million people are subject to human trafficking around the world, with children comprising one of every four victims. In many cases, the victims are used and transported by their traffickers in supply chains. 

Tim Nelson is the international development director for Hope For Justice, an anti-trafficking organization that aims to end modern slavery. He also holds the same title at the Slave-Free Alliance, an affiliated group that collaborates with businesses to assess and prevent the risk of human trafficking in their supply chains. Nelson recently appeared on RIMScast to discuss the how human trafficking has evolved into a major supply chain risk and how employers and employees can identify signs of this abuse.

Check out some highlights below, and to take a free deep-dive with Nelson and learn how to take action to prevent human trafficking in your company and community, download RIMScast episode 120.

For more information on steps businesses should take to help identify and combat modern slavery on their premises, you can also check out the Risk Management feature article “Human Trafficking: How Businesses Can Combat the Modern Slavery Epidemic.”

What inspired the creation of the Slave-Free Alliance?

Tim Nelson: We primarily started in the U.K., and formed because of the Modern Slavery Act, which requires companies with £36 million (about $50 million) or more in their annual revenue to state their efforts to remove slavery from their supply chain. Consequently, we tend to work with businesses above that £36 million level and we try and effectively help them honor their commitment.

We also work alongside federal or local police and alongside other NGOs and effectively try and be a trusted friend. Many people, because of the countries that they come from or what they’ve been told, are suspicious of police or are worried about corruption. We can be there to build that bridge of trust.

How can someone identify trafficking and modern slavery?

TN: Traffickers are those individuals who would use other people to generate profit for themselves and are looking for every opportunity. Global estimates indicate that there’s $150 billion made from this illegal activity. And therefore, the traffickers have thought it through. 

One of the complexities in identifying it is that human trafficking is hidden in plain sight. The common form that most people are aware of is sexual exploitation. But ultimately, traffickers [also] realized that they could traffic individuals to work in the supply chains of businesses, making components, working in manufacturing, working in agriculture.

Could you provide an example of how traffickers permeate supply chains?

TN: Last year there was a case where 400 victims were identified as being slaves within the primary supply chain of some of the major supermarkets within the U.K. And, like we said earlier, it was in plain sight—no one could see how this was happening.

This particular occurrence happened because the traffickers had gotten control of a recruitment company and they were able to bring individuals from a non-English-speaking nation to the U.K. Those individuals were given jobs, but the traffickers had control of their bank accounts. They were forcing these 30-plus individuals to live in a three-bedroom property. Many of them were washing themselves in a local river—not having running water was a sign that this is not how people should be living in 2020. 

National Slavery & Human Trafficking Prevention Month is held annually in January to educate about the different forms of human trafficking. What can risk professionals do to ensure the awareness continues all year?

TN: I would encourage all businesses to realize that they’ve got the power to change this so easily if they start to engage and put in different processes and systems. And part of what we’re trying to do is not to just encourage individuals or companies to stop buying goods from a particular company. If you just stop dealing with a company because you suspect there’s modern day slavery or trafficking happening, that company will close and another one will open like a phoenix. Companies can also sometimes be complicit just by not even looking or allowing enough due diligence to show that they are slave-free within the supply chain.

Is there a bottom-line impact as well?

TN: What we are seeing now is, internationally, inaction can be a major risk to your business. I can think of companies where issues around slavery were brought to the fore and share prices dropped by half as institutional investors pulled out. This is a key ESG issue, which makes it a C-suite-level risk in many cases.

What should companies expect when they engage with the Slave-Free Alliance?

TN: The first thing that we would do is conduct a gap analysis. This is not just looking at where you’re getting supply from—it’s to try and identify the weaknesses that may be in your supply chain. And that gap analysis forms something almost like a risk register.

Every company is different. I spoke to a Fortune 100 company last month that didn’t even have a procurement division. And that’s what I would have assumed every major multinational had. But every company has a different approach to it.

Quite often, a lot of people find that the even the thought of how big their supply chain creates a massive complexity because there might be just three people running the procurement department.

When we see something that would sit within the risks that we identify, then we work with the companies to diminish that risk. It could be an [unannounced] site assessment or working with those people who are going in and auditing the factories themselves.

For more information about how your business can combat and identify modern slavery, visit the Slave-Free Alliance and Hope For Justice. You can report suspected activity in the U.S. to the National Human Trafficking Hotline and internationally to the International Labour Organization.

On Data Privacy Day, Catch Up on These Critical Risk Management and Data Security Issues

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Happy Data Privacy Day! Whether it is cyberrisk, regulatory risk or reputation risk, data privacy is increasingly intertwined with some of the most critical challenges risk professionals face every day, and ensuring security and compliance of data assets is a make or break for businesses.

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In Cisco’s new 2021 Data Privacy Benchmark Report, 74% of the 4,400 security professionals surveyed saw a direct correlation between privacy investments and the ability to mitigate security losses. The current climate is also casting more of a spotlight on privacy work, with 60% of organizations reporting they were not prepared for the privacy and security requirements to manage risks with the shift to remote work and 93% turning to privacy teams to help navigate these pandemic-related challenges. Amid COVID-19 response, headline-making data breaches and worldwide regulatory activity, data privacy is also a critical competency area for risk professionals in executive leadership and board roles, with 90% of organizations now asking for reporting on privacy metrics to their C-suites and boards.

“Privacy has come of age—recognized as a fundamental human right and rising to a mission-critical priority for executive management,” according to Harvey Jang, vice president and chief privacy officer at Cisco. “And with the accelerated move to work from anywhere, privacy has taken on greater importance in driving digitization, corporate resiliency, agility, and innovation.”

In honor of Data Privacy Day, check out some of Risk Management’s recent coverage of data privacy and data security:

CPRA and the Evolution of Data Compliance Risks

Also known as Proposition 24, the new California Privacy Rights Act (CPRA) aims to enhance consumer privacy protections by clarifying and building on the expectations and obligations of the California Consumer Privacy Act (CCPA).

Frameworks for Data Privacy Compliance

As new privacy regulations are introduced, organizations that conduct business and have employees in different states and countries are subject to an increasing number of privacy laws, making the task of maintaining compliance more complex. While these laws require organizations to administer reasonable security implementations, they do not outline what specific actions should be taken. Proven security frameworks like Center for Internet Security (CIS) Top 20, HITRUST CSF, and the National Institute of Standards and Technology (NIST) Framework can provide guidance.

Protecting Privacy by Minimizing Data

New obligations under data privacy regulation in the United States and Europe require organizations not only to rein in data collection practices, but also to reduce the data already held. Furthering this imperative, over-retention of records or other information can lead to increased fines in the case of a data breach.

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As a result, organizations are moving away from the practice of collecting all the data they can toward a model of “if you can’t protect it, don’t collect it.”

3 Tips for Protecting Remote Employees’ Data

As COVID-19 continues to force many employees to work from home, companies must take precautions to protect sensitive data from new cyberattack vulnerabilities. That means establishing organization-wide data-security policies that take remote workers into account and inform them of the risks and how to avoid them. These three tips can help keep your organization’s data safe during the work-from-home era.

What to Do After the EU-US Privacy Shield Ruling

It was previously thought that the EU-US Privacy Shield aligned with the EU’s General Data Protection Regulation (GDPR), but following the CJEU’s recent ruling, the Privacy Shield no longer provides a mechanism for legitimizing cross-border data flows to the United States. This has far-reaching consequences for all organizations that currently rely on it. In light of the new ruling, risk professionals must help their organizations to reevaluate data strategies and manage heightened regulatory risk going forward.

The Risks of School Surveillance Technology

Schools confront many challenges related to students’ safety, from illnesses, bullying and self-harm to mass shootings. To address these concerns, they are increasingly turning to a variety of technological options to track students and their activities. But while these tools may offer innovative ways to protect students, their inherent risks may outweigh the potential benefits. Tools like social media monitoring and facial recognition are creating new liabilities for schools.

2020 Cyberrisk Landscape

As regulations like CCPA and GDPR establish individuals’ rights to transparency and choice in the collection and use of their personal data, one can expect to see more people exercise these rights.

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In turn, businesses need to ensure they have formal and efficient processes in place to comply with such requests in the clear terms and prompt manner these regulations require, or risk fines and reputation fallout. These processes will also need to provide sufficient documentation to attest to compliance, so if businesses have not yet already, they should be building auditable and iterative procedures for “data revocation.”

Data Privacy Governance in the Age of GDPR

As personal information has become a monetizable asset, risk, compliance and data experts have increasingly been forced to address the regulatory and operational ramifications of the rapid, mass availability of personal customer and employee data circulated both inside and outside of organizations. With new data protection regulations, Canadian and U.S. companies must reassess how they process and safeguard personal information.

Key Features of India’s New Data Protection Law

Among the new data protection laws on the horizon is India’s Personal Data Protection Bill. While the legislation has not yet been approved and is likely to undergo changes before it is enacted, its fundamental structure and broad compliance obligations are expected to remain the same. Companies both inside and outside India should familiarize themselves with its requirements and begin preparing for how it will impact their data processing activities.

‘Take-Home COVID-19’ Claims: Preparing for a Second Wave of Coronavirus Litigation

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The Spanish Influenza epidemic came in three waves, with the first hitting in March 1918, the second in the fall and the third in the winter of 1919. The U.S. Centers for Disease Control and Prevention considers the second wave to have been the most deadly. In the United States, well over half of the epidemic’s death toll of 675,000 occurred during the second wave. It is no surprise then that public health experts were already warning of the possibility of a second wave of the coronavirus pandemic when the world was just beginning to acknowledge that the first wave was upon it in February.

Personal injury mass litigation also comes in waves. Consider asbestos: In the first wave, individuals who worked directly with asbestos filed workers compensation claims. Workers exposed to asbestos in products filed products liability suits during the second wave. A third wave included “take-home asbestos” claims in which workers’ children and spouses sued for illnesses caused by exposure to asbestos fibers taken home from work. A fourth wave is now underway with the alleged asbestos contamination of consumer talc products.

The first wave of personal injury coronavirus litigation emerged in early March when a married couple sued Princess Cruise Lines for gross negligence for placing “…profits over the safety of its passengers, crew, and the general public in continuing to operate business as usual.” Many similar individual and class action lawsuits have followed. According to an analysis by the Miami Herald, some 3,600 cruise line passengers have contracted COVID-19 and more than 100 have died. 

The situation in nursing homes is far worse. Nursing home residents account for an estimated 40% of U.S. coronavirus deaths thus far. Predictably, wrongful death suits filed by the family members of nursing home residents are surging, even as some states move to shield nursing home operators from liability. Personal injury lawsuits have also been filed against hospitals, meatpackers, restaurants, grocery stores and warehousing operations.

However, as the first wave of the coronavirus pandemic subsides, personal injury litigation may subside along with it. But what if the pandemic has a second wave? Although there is a great deal of uncertainty, public health experts now believe that there is no inherent seasonality to COVID-19 itself, but they remain deeply concerned that a combination of complacency and greater indoor activity could lead to a second wave of infections in the coming months.

What would a second wave of coronavirus personal injury litigation look like? One possibility that modelers at Praedicat are considering is a wave of “take-home COVID-19” litigation arising from occupational infection, coupled with high rates of intra-family transmission. Praedicat modelers estimate that 7-9% of COVID-19 deaths in the first wave have been family members of workers in essential industries who acquired coronavirus at work. With widespread testing and improved contact tracing, take-home transmission could be relatively easy to demonstrate during a second wave. The first take-home COVID-19 lawsuits were filed in August against an electrical supply company and a meatpacking facility, and the precursors to these complaints are present in earlier lawsuits filed against Amazon and McDonald’s.

Many public health officials believe that it is entirely within our power to keep a second wave of the virus from forming while we wait for a vaccine to be developed and deployed. A unified and steadfast public health campaign is critical if we are to avoid a second wave, individual companies working to limit transmission among their workers and customers is as well. First and foremost, this means closely adhering to federal, state, and local guidelines and industry best practices regarding disinfection, screening and testing, social distancing, and the use of masks and other personal protective equipment. Employers might also work to raise awareness of take-home exposure and the risk to vulnerable older family members or those with pre-existing conditions like diabetes that have been shown to elevate the risk of life-threatening complications associated with COVID-19.  Depending on the circumstances, maintaining social distance at home may be just as critical as maintaining social distance at work.

While a second wave of the pandemic may be unlikely, some level of infection, illness, and litigation is sure to be with us until there is a vaccine. The best protection against liability is making the safety of workers and customers paramount. But risk managers need to prepare for the worst and should also be reviewing the availability of coverage for employment related coronavirus claims, including take-home exposure. The employers liability exclusion under a general liability policy, for example, might exclude claims made by the family members of workers.