Plotting a course to privacy awareness

Carnival UK employs a large workforce both onboard their cruise ships and in their shoreside offices. The needs of this diverse workforce coupled with a core vision to build and maintain consumer trust, led to Darren and his team devising a privacy training program that ensures all employees have access to the appropriate level of data protection knowledge that their role requires as well as encouraging a privacy-first culture across Carnival’s UK operations. Darren explains, “We want to make sure that the awareness training people receive is commensurate with their needs. A person whose role is to clean the ship’s public areas, for example, is critical to the success of our product, but they don’t need to know the detailed law around data protection. They should have enough underpinning knowledge that if they see something that looks like personal data unattended, they will know to take care of that information and ensure it is handed to responsible management.“

Carnival UK uses a blended learning strategy for its shore-side employees including its contact centre representatives, and more than 15,000 crew members. This blended approach consists of face-to-face sessions, targeted subject area sessions from the privacy team, as well as an e-learning component covered by OneTrust Awareness Training. The training program employs a tiered knowledge approach based on the level of data protection knowledge required within roles, with further training being provided for employees in key decision-making roles.

Taking privacy training onboard

Privacy training for Carnival UK’s employees begins during their induction into the company, through talks and presentations that highlight the importance of data protection to customers, employees, and the company. Darren notes, “Everybody receives a five-minute privacy induction as they join so that from day one, they know its importance to the business”. Further learning is delivered regularly through several resources – including the OneTrust Awareness Training tool – to ensure that a privacy culture can grow within Carnival UK and ensure that data protection is not seen simply as a tick-box exercise. Furthermore, the privacy team at Carnival UK has created a range of themed internal resources for employees to engage with, including posters, newsletter articles, and engagement activities targeted both broadly and within specific functions of the business.

Carnival UK relies on OneTrust Awareness Training for the e-learning element of their internal privacy training program. As well as providing employees with training modules relevant to their role, Awareness Training also helps to fulfil training obligations under the GDPR. At Carnival UK, all employees are required to take the ‘Data Privacy Essentials’ module as part of the training program, a benefit of which is its availability in over 20 different languages. Additionally, further role-based modules are used – such as ‘Employee Files’ in HR and ‘Call Centre Privacy’ in the contact centre – to ensure employees are supported with relevant knowledge to carry out their work. 

Smooth sailing with privacy training

Darren highlighted a number of advantages with the OneTrust Awareness Training. Having been initially developed by the IAPP, and since acquired by OneTrust, Awareness Training is seen as an accurate and trustworthy source of knowledge. Regular updates to the course content through OneTrust DataGuidance research ensures the Awareness Training content remains up to date. 

Further to its reliability, Darren also highlighted the accessibility of the Awareness Training tool as a major benefit explaining, “Successfully delivering learning outcomes in a shipboard environment presents challenges. The satellite internet bandwidth is limited and highly contended, not all of our crew have access to PCs, and we have had to take steps to ensure the training can be accessed on personal devices. Having a training course that is available in a number of formats including those compatible with our shipboard learning systems is critical to us.”

Additionally, Awareness Training boasts several privacy essentials modules that are available in multiple languages. This allows flexibility for Darren and his team to offer some e-learning privacy training to employees in their native languages for maximum comprehension of the course content.

Darren and his team at Carnival UK have developed an in-depth privacy training strategy – including the use of OneTrust Awareness Training modules. The program is targeted at educating Carnival UK employees with relevant knowledge of the data protection landscape beyond just a compliance exercise. Accessibility to the Awareness Training course content has helped build upon Carnival UK’s core vision of building and maintaining trust through handling data in a compliant manner. Furthermore, Darren has been able to automate and manage many other aspects of the company’s privacy program through the use of OneTrust tools including Assessment Automation, Privacy Rights (DSAR), and Cookie Compliance.