The most important step for the HR department to take when implementing this new software is to provide notice to employees that their emails will be scanned by the software and creating automated profiles. This is because the software involves the collection and use of personal information from employees, which may implicate their privacy rights and expectations. By providing notice, the HR department can inform employees about the purpose, scope, and consequences of the software, as well as their choices and rights regarding their data. Notice is also a key element of transparency and accountability, which are essential principles of privacy management. Providing notice can also help the HR department comply with various privacy laws and regulations that may apply to the software, such as the Electronic Communications Privacy Act (ECPA), the Stored Communications Act (SCA), the Fair Credit Reporting Act (FCRA), and state privacy laws. Notice can also help the HR department avoid potential legal risks and liabilities that may arise from the software, such as claims of invasion of privacy, breach of contract, or violation of employee rights. References:
* U.S. Private-Sector Privacy, Third Edition by Peter P. Swire, DeBrae Kennedy-Mayo, Chapter 4, Section 4.2.1, pp. 97-98.
* U.S. Private-Sector Privacy, Third Edition by Peter P. Swire, DeBrae Kennedy-Mayo, Chapter 5, Section 5.2.1, pp. 125-126.
* U.S. Private-Sector Privacy, Third Edition by Peter P. Swire, DeBrae Kennedy-Mayo, Chapter 6, Section 6.2.1, pp. 153-154.
* IAPP CIPP/US Certified Information Privacy Professional Study Guide by Mike Chapple and Joe Shelley, Chapter 4, Section 4.1, pp. 113-114.