SMART—WRITE YOUR OWN DRAFT

To save on legal fees, generate the first draft of your policy yourself. “We drafted our policy in-house and then asked legal counsel, ‘Is there anything we’re missing?’ ” says Case Sosnoff, chief compliance officer for the Chicago brokerage Tastyworks. “That also helps you understand the verbiage, the legality behind it all.”

Hartert looked at his competitors’ policies and those of similar companies in the E.U., Asia, and Australia. While they may be good models, don’t copy them verbatim, says Robert Braun, a partner at Jeffer Mangels Butler & Mitchell in L.A. “No two businesses are exactly alike. There’s a reason why you’re someone’s competitor,” he says. To ensure your policy will reflect your unique needs, get input about current and future privacy concerns from your leadership team. “Our vice president of customer operations, our vice president of product, our CTO, and our vice president of finance all collaborated,” says Ankur Nagpal, founder and CEO of Teachable, a teaching platform based in New York City. “At the end of the day, the policy will affect all those stakeholders.”