Have you ever received a message from a company you do business with that your data may have been compromised? How did that make you feel? I think most of us have been there, and you feel helpless. At that point, there’s nothing you can do. You can take steps to avoid such a breech in the future and set up credit monitoring, but it doesn’t erase what was done. Once the cat is out of the bag, there’s no putting it back in.
Similarly, all companies have confidential information. This is usually what gives them their competitive edge. Sometimes it has to do with how they manufacture their product, and sometimes it pertains to the composition of their product. Perhaps they have some special whiffle dust that gives their product superior performance. If a company decides not to patent this information, then they will want to protect their trade secrets from getting into the hands of their competitors.
What is the best way to protect your confidential information? One way is to keep that information on a need-to-know basis. You may be concerned about your confidential information when filling out surveys from your customers. Similarly, your vendors may be concerned about providing you with confidential information. It can get rather confusing when trying to provide everyone with the details about compositions that are necessary in order to determine regulatory compliance, but still protecting trade secrets.
In my blogs in September and October, I discussed filling out customer questionnaires and also industry banned and restricted lists. This month, I wanted to focus on how these can be completed while still trying to protect confidential information. One way is for the two parties to establish a secrecy agreement. However, in the absence of such an agreement, there are other ways to maintain confidentiality.
My first recommendation is to never disclose the raw material product names that you are purchasing. Instead, combine all of the substances in all of your raw materials, and submit the information to your customer at the chemical substance level. Preferably, this would include the Chemical Abstracts Service (CAS) number for each substance. If you think there is a particular chemical substance that is proprietary you could enter it as a generic chemical identity. That said, chemicals that have hazards, should be disclosed whenever possible. If you believe that you would rather not identify a specific hazardous substance, then you should at least present all the information on the hazards and all the regulatory information.
In the situation where you are receiving compositional information from your supplier, you must protect all of their confidential information, and you will need to establish safeguards so you don’t accidentally disclose their proprietary information to anyone.
Handling confidential compositional information can be tricky. If you need some assistance, reach out to us at Strategic Realm Consulting. We’ll be glad to help. We will work with you to develop cost-effective and risk-based approaches. Then we will teach you how to maintain your processes. Contact us for more information.