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Blog: Disclosure Policies and Data Security: The Safety Net Within Data Sharing Programs

Disclosure Policies and Data Security: The Safety Net Within Data Sharing Programs

If you run a trade association, your organization may be uniquely positioned to provide the leading source of information on key market size and trends for your sector. By implementing a customized program that collects, analyzes, and reports in the aggregate on highly confidential member data, you can produce industry market research that provides crucial business intelligence on trends and competitive movements within your sector. This type of market research is invaluable for members, association leadership, and other key industry stakeholders.

Confidentiality is one of the most important aspects of an association-sponsored data program. Vault partners with trade associations to produce this data while simultaneously following antitrust regulations set forth by the Department of Justice (DOJ).

We work with association clients to develop disclosure rules.

To ensure all member companies remain in compliance regarding anti-trust regulations, Vault has a set baseline policy for all data programs; however, beyond the baseline, the rule structure varies from client-to-client. In more basic terms, Vault customizes disclosure rules for each client, in which case the adopted rules are largely dependent on the level of scrutiny the DOJ imposes on a client’s particular industry.

According to Vault Manager Jacob Sweeney, Vault sees both sides of the spectrum, “we rely on our clients to set the tone for data publication stringency. Association clients who are more sensitive to scrutiny from the DOJ will have a stringent threshold; whereas, some industries are not as stringent.”

We take great precautions evaluating data.

Keeping data safe is no easy feat. Vaulters go through multiple rounds of disclosure analysis to assure that no one participating company’s information has been compromised. During disclosure analysis, Vault reviews categories or specific lines within a report to determine what can or cannot be published. Anything outside of the program’s disclosure rules is hidden from the final results.

We have a process established for mitigating disruption in disclosure policy.

Vault has a formalized process to tackle data that can expose too much information. “For instance, if a company has a market share that is greater than the amount set forth in the disclosure rules, without telling participants their exact market share, we let them know they’re above the rules in the disclosure policy and give them options to publish, remove, or combine lines,” illustrates Sweeney. Having options empower participating companies and keep them in control as to what extent they want their information to be perceivable.

Combining lines is a fair option for participating companies; unfortunately, as Sweeney describes it, “there won’t be the same granularity or detail.” Still, sometimes this is necessary to either protect the interest of the individual company or the entire industry.

In essence, disclosure rules give companies the confidence to participate in data sharing programs while also shielding them from revealing their organization-specific data. While disclosure rules limit what can be published on a report, they give members the incentive to participate and the assurance that their participation will not result in a violation of anti-trust regulations.