Program Management

Data privacy program management involves the overall strategy, planning, implementation, and continuous improvement of an organization’s data privacy program. Taken together, the individual elements described in this model serve as a good approximation of a data privacy program, but the whole of a privacy program is more than just the sum of its parts. This element represents the holistic, end-to-end management of a data privacy program, inclusive of the elements described in this model and of any other elements unique to your organization. This includes the coordination of the different components and activities that make up the program, as well as the allocation of resources and the management of stakeholders.

Less Mature

An immature data privacy program management process is characterized by ad hoc, reactive, and disjointed efforts to address privacy risks and compliance requirements. The organization may lack clear ownership and accountability for the program, as well as a comprehensive and cohesive privacy strategy. The program may also be under-resourced, poorly documented, and not regularly evaluated or updated. You may pursue individual activities (such as those described in this model) but struggle to prioritize one over the other or find that as you progress in one area of data privacy, another area suffers.

More Mature

In contrast, a mature data privacy program management process is characterized by a proactive and strategic approach to privacy risk management and compliance. The program is well-defined, well documented, and regularly evaluated and updated. There is clear ownership and accountability for the program, with dedicated privacy professionals or teams leading the effort. The program is supported by sufficient resources, including personnel, technology, and funding, and has the buy-in and participation of all relevant stakeholders. You’ll have identified priorities and established a systematic approach to growing and maturing your privacy program, and you will track its growth over time.

Recommended Next Steps

To improve your overall privacy program management, privacy professionals can take several actions, including:

• Develop and implement a comprehensive and cohesive privacy strategy aligned with the organization’s overall business strategy and risk appetite.
• Establish clear ownership and accountability for the privacy program, including dedicated privacy professionals or teams, and a governance structure that includes regular reporting to executive management and the board.
• Allocate sufficient resources, including personnel, technology, and funding, to support the privacy program.
• Conduct thorough research and evaluation of potential tools and vendors, including the potential privacy risks they will introduce.
• Provide ongoing training and support for the effective use of selected tools for any stakeholders who may interact with your privacy tech stack.
• Ensure the selected tools integrate with existing systems and processes and can be scaled as needed.
• Develop and maintain comprehensive policies, procedures, and guidelines that are regularly reviewed and updated.
• Conduct regular privacy risk assessments and develop risk management plans to address identified risks.
• Implement appropriate privacy controls and measures, including data protection measures and incident response plans.
• Provide regular privacy training and awareness to all relevant employees, vendors, and contractors.
• Regularly monitor and measure the effectiveness of the privacy program, including the identification and tracking of privacy metrics and key performance indicators.
• Foster a culture of privacy throughout the organization, including the active participation of all relevant stakeholders, such as business units, IT, legal, and compliance.
• Stay up to date on emerging privacy risks, legal and regulatory developments, and industry best practices, and incorporate these into the privacy program as appropriate.
• Regularly assess your privacy program using this model and other frameworks and systems as appropriate.