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Episode 4: Legal by Design: A Human-Centered Approach to Privacy & Collaboration

Today's guest, Giorgia Vulcano, Global Digital Ethics Manager at AB InBev, uses a human-centered approach to data and privacy. It’s an approach centered on true moments of collaboration and co-creation between legal and non-legal teams.

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Nick Cucuru

VP of Advisory Services at Privitar

Giorgia Vulcano

Data Ethics Officer at AB InBev



Georgia: and really started to think together with them and brainstorm how we could you know, really create solutions that not only were convenient and and efficient had, you know, spectacular user experience but would also be compliant and legal by design.

Intro: Welcome to In:Confidence, the podcast for data ops leaders. In each episode, we asked thought leaders and futures to break down the topics and trends concerning it and data professionals today, and to give us their take on what the data landscape will look like tomorrow. Let’s join the data conversation.


Nick: I’m Nick Cucuru, and this is the In:Confidence podcast sponsored by Privitar. incompetence is a community of data practitioners that encourages conversations that will enlighten, educate and form data leaders of today and tomorrow. Thank you for taking the time to let incompetence be a part of your day. Today, joining our community is Georgia Vulcano. She’s a data privacy and pioneer. And she is the data ethics officer for ABM InBev, Georgia developed the legal design framework which gives structure to the relationship between legal and business leading to Yes, we can conversations instead of no you can’t conversations. She also has a video legal by design, outlining how to create innovation, stay compliant and partner with business. You can get links to both that video legal by design as well as the legal design framework in our podcast description. Georgia, welcome to the In:Confidence community. 

Georgia: Thank you very much, Nick, and thank you for having me here today. 

Nick: Oh, this is going to be a pleasure. I mean, Georgia, you have a very unique data and privacy journey in your career. Can you take us through it a little bit, because again, what a great background you have.

Georgia:  Absolutely Nick. So I started my career as a human rights lawyer. I was in Costa Rica first. And then Childe. And I mainly worked on human rights violation cases committed by the military dictatorships in law time. And I worked on cases where the victim had been persecuted because of their opinions because of what they believed in. And were therefore subjected to targeted surveillance, which often dramatically led to their death or to their physical impairments. So it has been a huge critical experience for me, where I learned so much about not only the implications of privacy violations, but about the concept of empathy, which, for me, it really shaped me as as a lawyer, and it really impacted my path moving forward. And, you know, empathy today is probably one of those buzzwords, right, we hear it a lot, we hear it a lot in design thinking. But the way I learned about this concept was from a social perspective, and something that I always say is that there’s nothing less empathetic than a dictatorship regime that’s really persecuting and unequally eating its own population. And, and so that was my my sort of career. And whilst I was in Chile, I realized that I learned, which maybe comes to you as a surprise that at least it did to me that Chile is a pole of innovation in Latin, it’s kind of like if we want to compare it to some other reality. It’s kind of like the Silicon Valley of the time. And so I got more and more exposed to the startup ecosystem. And I began working both as an in house and as an external counsel with with different startups. I was working very closely with the CEOs with the developers with the marketeers, I was practically the only lawyer. And so I really had to start changing my way of thinking, my way of communicating my way of working to make sure that I could really help the startups creates value in a sustainable and human centered way. And this lowlevel made magic to my role as a lawyer, but also it was it was critical, because it exposed me for the first time to the concepts of design thinking and agile methodology, which actually are, you know, something that today have a huge impact on my way of working and that, you know, we will see later on with the legal by design framework. 

Nick: What’s interesting about that is, you know, you’re probably you took it from a different perspective, the human, to your point, human centered perspective of privacy and business. Whereas most of the people that we work in the, you know, the data offices or the chief data officers or privacy officers, come at it from the legal and business side. What kind of myths in your career Have you been able to challenge when it comes to how legal and business should be relating or talking with or collaborating with each other?


Georgia: That’s a great question. And look, I have to start with my own myth. I think I had to overcome overcome many of those, you know, I always thought that as a lawyer, I was that external legal adviser that needed to have you know, a certain distance from the business and make sure that it could provide, you know, the best possible advice. And so we are educated during university, right, like as lawyers. So that’s how we are prepared. And, you know, in these collaborations, and my experience, actually learned to become a creative team member, you know, I kind of like, overcame that myth of being the lawyer that kind of like, it’s called in at the very end, having to kind of like give the greenlight having often to say no, or being the one that, you know, kind of like, kills the passion. That’s how I’ve seen myself for so long, to becoming, you know, like, really, that the creative team member where, you know, I sit down with the rest of the team, be it the developers and marketeers and people from human resources from r&d. And when he started, like to think together with them, and brainstorm how we could, you know, really create solutions that not only were convenient and efficient or had, you know, spectacular user experience, but that would also be compliant and legal by design.

Nick: So when you take a look at that, again, what a great, great work right approach to it. The regulations and the privacy laws that you are working with those people on, in the last two or three years with as many new privacy laws, as many new regulations are happening. You know, are there any hints or things that you could talk to people about how people should be thinking about that collaboration or some tips and tricks, you know, when you’re in those meetings, that upfront things that, you know, they should be thinking about? Or asking the right questions, or which questions should they be asking? When they’re collaborating with each other? 

Georgia: Absolutely, like, let me start by saying that the privacy laws and regulations that we’re seeing today are a reflection of social awareness and what we value as a society. And a regulation like the GDPR really forced all market players, first of all, to abide by the same rules kind of like setting that standard. But secondly, it really shifted the focus on digital ethics on the redistribution of responsibility and accountability amongst all players. And so I think that today, we have a huge challenge, in terms of, you know, putting the data subject the individuals at the very center of what they are, what we do, and ensuring that we can actually really innovate in a way that is human centered, that is future proof that is sustainable, that kind of like fulfills the value expectation of our users without compromising, you know, the privacy and the data ethics. And so when I think about all of this, it’s a mouthful, it’s like, there, it’s so complex, there’s so much that we need to do. That’s, my first thought is, as a lawyer, or as a single function, I cannot possibly address this on my own, but it needs to join forces with all other functions, I need to be able to have a multi-perspective over these challenges and problematics, in order to make sure that we can really deliver products or services that are ethics by design, legal by design, and that really embeds all the benefits and all the values that are important for our end users. 

Nick: You know, Georgia, it’s no wonder why, you know, based upon your career, how, you know, in our last conversation he’s talked about people look at zeros and ones as data. And as a data scientist, that’s what kind of look at it zeros and ones or data. But your perspective is those zeros and ones are actually a person. It’s a digital persona that represents people. And it’s no wonder this legal by design framework that you created is very human centered. It’s a different approach. And yet, I really liked the approach. Can you walk us through that legal by design framework, and maybe even come up with some examples how you’ve effectively abused it in your career? 

Georgia: Absolutely. Nick, that’s, that’s a great question. Look, the legal by design framework. First of all, let me say it’s a working tool. And it’s meant to guide teams in their collaboration and discussion processes, kind of like helping them to build and share a common language. And what it does is that it combines the Double Diamond, which is a methodology, typically using design thinking, for problem discovery. So it’s probably something that both you and our audience already aware with. And it combines that double diamond with the Irek formula, which is a formula typically used by lawyers to address and solve a legal issue. And so what the legal design framework does is not only identifies what are the touch points between the legal and non legal teams, but it also describes what is going to be the input of the legal teams at every stage of the project so that it’s really understandable to the whole team. 

Nick: So when you talk about the legal by design framework, and it’s a double diamond. You know, the ability to actually bring legal in at certain points, as the development happens, how have you effectively use that in your career, you know, to have, you know, the ability to say yes, or help the design team as they move forward?

Georgia: Absolutely. I very much used it in projects that had a very high degree of complexity and uncertainty. So I mainly used it in projects where we were using new and emerging technologies. And where, you know, we didn’t have previous learnings from other projects, we didn’t have possibly the case law, we didn’t have necessarily the rules developed around this. And so in that case, is legal by design framework was, was very useful, not only to make sure that, as a lawyer, me and my team would be involved at the very early stages, but it also was an opportunity to really look step by step, what were the legal challenges that were arising with the projects and how we could best address them to ultimately deliver a solution that would be legal by design? And, look, it’s a tool that it’s really, it’s ready to be used. It includes instructions, it includes top block of questions, it includes activities that teams can do to work together. And it’s open source, you mentioned it earlier, right? If people can find it in my LinkedIn profile, they can just take it and start using it and applying it. 

Nick: You know, when you think about it, what I like about the framework is there’s no potentially no gotchas along the way. And it’s what you said, it’s collaboration, where legal is working with the product teams that they’re working with, you know, whether it’s software developers, product teams, or whatever. Are there some things that can smooth out that collaboration, that the framework helps people, you know, do as you said something about, you know, having the same language? Are there other things that the framework allows people to avoid? You know, or I should say, you know, avoid the pitfalls, that sometimes happens on projects. So we have common language, what other things could be out there that the framework takes care of? 

Georgia: Okay, I think that the legal, but is our framework really helps to create a formal moment of collaboration, right? Usually, what happens is that I get it, at least in the experience that I’ve had is that lawyers are pulled in at the very end of the project. So most of the times they kind of like Miss on, what was the rationale behind certain business choices, the Miss on what is really like the big pictures and the big picture and the objectives that we’re trying to pursue. And so by involving the lawyers at the very early stages, the lawyers can also understand, you know, what we’re trying to do, and what’s the best legal solution to enable that that objective? So I think that’s having this formalized approach and making sure that the lawyers are involved, from the very beginning all the way through and not, you know, at some stages, but others? I think it’s kind of like it’s a really it’s it’s a critical enabler. 

Nick: Well, there, you know, and I think those two or two two points are really important. It’s the rationale slash the intent that people are having as they move through the process. And it’s creating that common language where people can understand instead of just getting caught up in their own little terminology. So I think that’s what I like about the framework itself. And I like about having the collaboration throughout the process, which, again, is a big pitfall that I’ve seen, just in the work I’ve done. So I think those are those are great. Now, with the design, the legal by design framework, one of the things and you’re going into this at InBev, is the role of legal and the challenges that we’re starting to see with ethics. And ethics is not something that is, you know, GDPR or CCPA, or whatever, within compliance, it’s actually starting to go down that ethics, that ethics route. So when you take a look at that, when it comes to data innovation and changing, how is ethics starting to play into people’s ability to innovate people’s ability to, you know, do product development, or serve their clientele, their constituents, or their stakeholders? 

Georgia: That’s a big question, Nick, but like, let me start by by saying that, like, I think that’s today’s interactions that we have with technology are much more sophisticated than what we had before. Right? I mean, we went from having phones that could Max receive emails to having like real smart devices that can, you know, monitor the security of our homes, or make payments, right? And so the machines and the mechanisms that we are interacting with on a daily basis are becoming much, much more complex. And so are the uses of the data that’s being made that it’s also becoming, you know, much, much broader at so are the benefits. And so, you know, today we’re using AI for personalization. We’re using it to diagnose diseases to detect tax evasion, approval, loan, scream, job candidates. I mean, there are many as User’s. But I think that one of the challenges we have is that we cannot always control what information is being used, how it’s being used, when we can delete it, and overall, what is going to be the impact on our lives. And this, I think, is really the challenge that we have with technological progress, right? It can create amazing life improvements. But at the same time, if it’s not used properly, it’s gonna create something, it’s a word I heard, and I love, but it’s gonna create a tech lash, right, it’s gonna cause or trigger possibly adverse effects on our society and ultimately pose risks to our rights and freedoms. So as a result of this, as a result of these challenges, and of this complexity, we are seeing an increase in calls for the development of ethical principles, norms, and frameworks, that can really help us understand how we can, you know, deliver the benefits of technology in a way that is fair and just undistributed fairly, but without, you know, being weighed by the risks that those may cause. And so I think that’s, you know, this is the the big challenge that we have. And this is where digital ethics plays a critical role plays and will be playing a critical role in the next years. And so, the way I see digital ethics is that it’s really what enables us to reach consensus on what is the you know, the right balance between what we want to do, and our way of thinking and the values that we commit to. And I think that one of the things also that we will need to really take into account is the local mindsets, the local cultures, I think that today, we tend to look very much to global standards. But we don’t necessarily, you know, synchronize with local culture, mindsets, and also values. So I think that’s also going to be a big, a big challenge for us to achieve in these in these next years. 

Nick: It goes back to some of our past conversation, and even what you’ve also said before, the and I like what you in our conversations, we just like ethics, there’s a word in there empathy, that you bring into this concept. And, you know, when you talk about artificial intelligence, you talk about machine learning, and even deep learning, for that matter. I like when you say there, someone’s still needs to be watching that empathy is not going to be there and a formula, that empathy is still going to be that human factor. And that’s where I think, you know, your design framework comes into play very well, knowing the intent, as you have said, and that the ability for someone to have that empathy, as you said, even not just globally, but also locally, when you take a look at that. So I’d like to try to dive a little bit into when you start to think about empathy, and ethics and the design framework that you go, you know, how should we be looking at the ability to keep, you know, when we do our review of models? How do we keep that at the forefront of what we should be doing? You know, again, it’s really easy to get lost and and not have that ethical view, or that empathetic view? What are the things that we could be thinking about as we continue not just building the model? But when we’re running the model? Are there certain things that you’re like, hey, here’s some, you know, again, some tips and tricks are things that we should always be thinking about, as we review our work?

Georgia: Sure. So look, I heard a phrase that I loved earlier, a couple of days ago, and it said that, you know, the pace of change has never been this fast. But again, it will never be this slow. So like this is really the time to think and reflect about, you know, how can we design emerging technologies in a way that is truly human centric and ethical, and that has really this empathy?  It’s hard. And, you know, I remember, Steve Jobs used to say that, you know, when we talk about design, we need to mention Steve Jobs. But he used to say that, you know, you got to start with the customer experience and work backwards to this technology. And I think that this approach, the same principles apply here, too. I think that we need to think about, really, what are the benefits that users need that they’re looking for? And how can we design products and services that deliver those benefits in a way that it’s that it’s fair? So I think that if I would have to, you know, pose a question for teams, it would be to, you know, start thinking about how can we enable consumers to act ethically? 


Nick: That’s actually interesting. I like that. And I also like, when you talk about the consumer, what you said also before is you got to think of the consumer, not just from a global perspective, but the individual culture itself. What is very successful in probably communicating or building models, let’s say in the US may not work in Chile, it may not work in Argentina, it may not work in Belgium, where you’re at it may not look working Roma, right? I think that I think that’s the part that in our last conversation really struck me is, it’s that global view that you have, that your design framework has. But it’s then applying it to the local. And that’s to me, one of our biggest disconnects that we have today is, is I just want to solve this one problem, but I’m not willing to go that next step saying, how does it solve for this particular culture, these particular types of people, and I think that’s where your journey of being a human rights lawyer is really, you know, it’s a very unique journey to get to where you’re at today, especially within data and privacy. When we take a look at these global organizations, I’m gonna get to a question here in a minute, I promise, when we get to look at these global organizations, and even going into your new position at InBev, are there things? Or are there ways that we should be looking at how to get closer to the people in certain areas? You know, how do you get from that global view? down to that local view, which you have done successfully? In your career? How do you structure those types of conversations or help teams get their sick get themselves to look at things like that? 

Nick: That’s an amazing question, Nick, I love that. Look, I think that’s a starting point is to have teams that are truly diverse, you know, that really bring these multi perspectives. And it goes in many different ways. You know, it goes from the country that you come from, it goes from your, your history, it goes from your experience, it comes from, from many different factors. So I think that that’s definitely something that we, we have to do, we need to really interact with, with many different regions, and not just have a kind of like, not just addressing issues from, you know, with with Western lenses, but we need to go broader than that. So I think that’s definitely one step. And secondly, look, something that I would recommend teams to do is to sort of understand how their products and services are being used, like how really consumers are, are interacting with those, you know, when your product has a sealer? What is being done with that sealer when you know, when you’re you’re making a pizza? Where does the carton of the package of the pizza go? Is it used for a science project is it used to, you know, store food, how it’s being used, like really understand, from the beginning to the end, how products are being at services are being used. And I think that that really gives you a different perspective and a different look, and maybe a more empathetic one, on how products are really benefiting our end users to actually use data to understand more about the use of how people use your products and services. 

Nick:I like that being a data scientist myself, using data as uncover and unlock some of those views. Give it a nice view of what the culture is looking at. So as you think about it, we think about the legal design framework. And we think about the collaboration where illegals coming into the picture a little bit earlier, are actually earlier in the process. What are some of the takeaways that you want our listeners to have today? With they want to look at that legal by design framework, if they want to talk about collaboration, or pitfalls, what are those main takeaways that someone should walk away with from our conversation today? 

Georgia: Look, I think that there, the major takeaway that would have is that, you know, the world is waking up, we are becoming more and more aware of the implications of technology, we are becoming much more sensitive to the environment, to the way we live, we work we consume. And so when we talk about reflecting those values in the products and services that we create, it’s not just about making better products, but it’s also about evolving as a society. And, you know, my husband said something that I thought was amazing. He said, we can’t possibly do to the Mars and to the moon. what we’ve been doing in LATAM and in Africa.

Nick: that’s actually really good. That’s a very good perspective on it. So when you think about that, what are the changes that you would hope that people you know, if they go to the legal by design framework, or even the changes that you’ve gone through? What are the changes that people can potentially start on Monday or Tuesday, you know, the beginning of their week or tomorrow, for that matter? What are some of those changes they could be making, to get them more into an empathetic, human centered, ethical view of how they use data, how data is used, and things like that? 

Georgia: Well, Nick I have a question back for you. And it would be like, you know, how many times you yourself, talk to the lawyers? How many times do you involve them? How many times per day you’ve actually talked to a lawyer? 

Nick: No, you know, I tell you it’s a good question because I think I, you know, when you talk about the Legal by Design Framework, I have a very unique perspective in when I worked at MasterCard, and that was we brought legal and to your point in the very beginning, and when we did product development, or we were doing projects, and that was unique. That’s why I loved when we got you as a person, because you were one of the pioneers, and being able to do that. But I gotta tell you, in my 20 years, we’ve been taught to legal until the very end, when the product was ready for rollout. And it just came down to do we got the right copyrights, to have the right patterns that we’ve applied for. And it made a big difference. And it really made a big difference when I found out that, you know, for, as you said, to have a yes, conversation, you know, you may want to do this and understanding the intent. While I’ll tell you what, how about, we can do it this way. And it still gives you the same results that you’re looking for, it’s just potentially in a safer, less risky way. And I think that was where my eyes became wide open. When I started to sit back and say they’re not the enemy, they actually are kind of looking out for me, like, I think you said a parent, like a parent, trying to help that child in the playground, you know, have have that and that, you know, enjoy the slides and the merry go rounds are whatever’s on the playground, but I’m watching to make sure that you’re protected. And I’ll keep you you know, in sight. So if you do stray away, I’ll bring you back to that original, you know, we’re originally trying to accomplish. So that question is a good question. I’ve actually seen this legal by design framework work, I seem to be very successful. And even in today’s where I work today, we do we bring those, those legal attorney, our attorneys and into the product development phase early on. So I can say, from what you’ve laid out what you’ve done, you know what it has been an enlightening last five years of my career, I’d be able to use a framework like yours legal by design framework.

Georgia:  I’m glad to hear that. Like, that’s, that’s fantastic. But, you know, empathy is really about putting yourself in someone else’s shoes. And so if we don’t have those interactions, those communications that that visibility from from everyone legal and non legal, if we don’t have those moments of collaboration and co creation, you know, I think that we go nowhere, we can’t possibly really achieve the type of innovation that we expect to achieve. And that, as I was saying before, it’s really, it’s sustainable, and it’s human centered. And so I think that really having a wider involvement and an interaction with legal on a daily basis, can really help start triggering that empathy. And uncertainty can also trigger a change in mindset, which I think is critical, right? Because at the end of the day, we’re talking about a changing culture and the changing way of working. 

Nick: So I want to switch gears as we wind down the conversation. And let’s have a little fun if we can. And you know, the big thing for me are actually going to be the one in another cup of coffee, boy, maybe it’s a nice Expresso. If I can go to a robot Cafe back in your home city of Rome. That’d be great. But this is where I’m at. So let’s have this little bit of fun. So if someone was visiting, visiting your hometown of Rome, Roma, what advice would you give them? When they go to Rome? 

Georgia: I would tell them to get lost to really get lost in the city of Rome, because I mean, it’s an open air museum, there is no other way to visit. I mean, first of all, the public transport for those who know Rome, isn’t at its best, but also really like walking through through Rome and getting lost through all those streets is just fascinating. I mean, for me, it’s still something that every time I go back home, I do. 


Nick: Well, you know, I liked that part of get lost, but my wife says Get lost to me. And it means a whole different thing. I like you’re getting lost in Rome. The site’s better. 

Georgia: Yeah. Mines more romantic I guess. Yes. 

Nick:  So if I have to ask is espresso or cappuccino for you. 

Georgia: So it’s absolutely espresso. And actually, I have to admit, I don’t like cappuccino. I’m actually ashamed. I think this is the first time I’m saying this. It’s really is very unpopular, but yeah, not a fan. 

Nick: Really? Okay. I’m an espresso person. So I’m with you. Now Cornetto or meritocracy. 

Georgia: First of all, I can’t believe you even found that. I mean, I’m flattered my thoughts. It’s like it’s amazing. It’s one of the best things ever, but I have to go,  I’ll go with the Cornetto. 

Nick: Really? Oh, yeah. Okay, favorite gelato? 

Georgia: Pistachio.


Nick:  Ah, really nice. Nice. Nice. All right. Well, Georgia. I gotta tell you, it’s been a pleasure of what a pleasure it I hope to have you on again, especially as you work through this whole world of human centered legal by design framework at AB Inbev. So I really look forward to hopefully having you here again. I could talk all day long, all day long with you. Maybe sipping a little espresso with a nice scoop of chocolate gelato for me.  What a great conversation this has been. So if I can listeners, don’t forget, you can get more details on the design framework and George’s videos by just using the links in this episode description to get there or go to her LinkedIn. So thank you for listening to In:Confidence, It’s a podcast for a community of data leaders where we’ve had Georgia Vulcano on today, where we’ve talked about human centered, ethical use of data as how you can innovate and still say yes, by using the design framework that she has she has put together so we can weave, enjoy your feedback. And you can provide your feedback to us at incompetence at that Once again, you can provide your feedback at and in confidence is all one word. Or you can reach me directly on LinkedIn or at Nick N-I-C-K dot Cucuru C-U-C-U-R-U While you’re out there giving us your feedback. If you can, why don’t you go out to the safe analytics resource hub, where you’ll find a variety of resources to help you maximize your innovation through safe data analytics. Or you can take the quiz on modern data maturity, and find out your level of maturity in data provisioning. Thank you once again for listening and spending time with the incompetence community. I look forward to our next conversation. Until then keep on innovating with safe data.

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