Program Building: Why its Worth Building an Actual Privacy Program

Why it’s Worth Building an Actual Privacy Program

If you already have a notice and a way to handle access or deletion requests, it’s fair to ask: why invest in more? After all, if a regulator comes across your organization, you are complying with law as it relates to your public stance. This isn't the entire privacy picture, however.

The first reason you might want to stand up a comprehensive privacy program is risk. Modern privacy laws and regulators don’t just ask, “Do you have a notice?” They ask whether your organization has reasonable and appropriate controls and can demonstrate them. That’s very hard to do with only a notice and an ad hoc DSR process. When something goes wrong, and that is an ever-increasing possibility in a growingly-interconnected world (e.g., a breach or a vendor breach, a regulator inquiry, a plaintiff's bar complaint), you’ll be judged on your privacy program, not just your cookie banner.

The second reason is efficiency. Right now, every privacy issue might feel like a completely new challenge. A new request, a new data‑sharing question, a new vendor, a new product idea, and each one solved from scratch. A privacy program gives you reusable patterns that you can apply again and again, like policies, playbooks, templates, and decision workflows. It reduces the cognitive tax on your legal, security, and product teams.

The third reason is trust and growth. Customers, partners, and potential acquirers increasingly ask pointed questions of companies. How do you manage vendor risk? What’s your retention schedule? How do you handle incidents? How do you govern AI? If your answers are improvised, you will feel it in delayed deals, tougher contract negotiations, and lower resilience when something goes sideways.

And the final reason is strategic. A privacy program isn’t just a shield. It's a competitive advantage, a way to deploy products and services faster with fewer surprises. When governance, data inventories, and playbooks are in place, your product and business teams can move with more confidence. You know where you’re allowed to experiment and where you need more caution. And you can communicate that to others through your confidence and with evidence.

This article covers some potential ways to get going in building out a comprehensive privacy program over three phases.

Remember, this article is for general information and education only. This is not legal advice. You should talk to your own counsel about how the law and rules apply to your specific facts.

Are You Starting From “Notice + DSR” Land?

Most organizations at your stage have three things:

• A privacy notice that was likely drafted around a law or a launch deadline.
• A basic way for individuals to exercise rights (an email alias, a web form, maybe a spreadsheet tracking requests).
• A loose “we’ll pull security in if something serious happens” approach to incidents.

What’s usually missing is everything that connects those parts together. It's much harder to execute on any of those three components without clear roles, data inventory and mapping, coherent policies and procedures, incident response and tabletop practice, vendor oversight, and a way to prove you’re doing what you say.

The good news is you don’t have to solve everything at once. Think in phases.

Phase 1 (Months 0–6): Build the Foundation

The goal of the first six months isn’t perfection. It’s to get you out of “ad hoc” mode and into “we know what we’re doing, and where the gaps are.” In practice, this phase focuses on three things: (1) governance, (2) visibility, and (3) a small set of critical procedures.

Start with governance. Name someone as the privacy program owner, even if it's only a part of their overall role. Give them a sponsor at the executive level who cares about risk and reputation and can function as a privacy champion. This might be your GC, CISO, CPO, or COO. Write a short privacy governance charter that explains what the program covers and who participates. It doesn’t have to be long, but it should outline, “Here’s who owns what,” so that privacy decisions don’t live in a vacuum.

Next, work on visibility. You can’t protect what you don’t know you have. Begin a lightweight data inventory that focuses on what systems hold personal data, what kind of data, why you have it, who owns each system, and which vendors are in the path. You don’t need a perfect data map, but you do need enough to answer the critical question of "Where would we look if a certain dataset was at risk, and who would we call?"

At the same time, turn your existing DSR process into something more repeatable. Standardize where you receive and process requests, how you authenticate requests, how you search for responsive data, and how you respond to individuals. Document a simple procedure, even if it’s just a page or two. That procedure can evolve, but having any written process is better than relying on memory.

Finally, give yourself an incident response backbone. You don’t need a 100‑page incident response plan on day one, but you do need to know who assembles when something happens, how you decide whether an event is a true incident, who owns legal and communications decisions, and when that balance of power shifts from one team to another. Create a short incident response plan that names an Incident Commander (or designates an Incident Response Team), describes your severity levels, and outlines what happens in the first 24–72 hours. Even a basic plan will dramatically reduce confusion if you get an unpleasant surprise.

By the end of Phase 1, you should have a named privacy lead and sponsor, a basic inventory of high‑risk systems and vendors, a documented DSR process, and a simple incident response plan. It won’t be perfect, but it will be a real start.

Phase 2 (Months 6–12): Connect the Dots and Close Obvious Gaps

Once the foundation is in place, the next six months are about operationalizing  your new program. Make sure the pieces you’ve built talk to each other and start to show up in daily work. This phase is when you move from “privacy is a series of one‑off tasks” to “privacy is part of how we make decisions.”

Begin by strengthening policies and aligning them with reality. Review your privacy notice against your data inventory and your actual practices. Does what you say reflect what you do? If not, adjust one or the other. Do the same with a small, focused set of policies, which might look like an internal privacy policy, an incident response policy (or playbook based on your plan), and a vendor risk/third‑party privacy review policy. At this stage, you don’t need a policy for everything, but you want clear expectations when it comes to your identified critical risks.

Then, bring privacy into the key processes that manage product and procurement. For product, create a simple intake and review pattern. It doesn't have to be fancy, just a short checklist that product managers or engineers can use to flag new features or data uses that may need a privacy review and a simple process for conducting that review. For procurement, add privacy questions to your vendor intake form and make sure your standard contracts include basic privacy and security terms, such as data use limitations, security commitments, breach notification, and cooperation. Create a guide that outlines accepted standard provisions and acceptable fallbacks. Anything else needs review and separate acceptance, and your procurement team can use this as a negotiation tool with vendors.

You should also start thinking about training. You don’t have to build a full e‑learning catalogue out of the gate. Start small by defining who needs privacy awareness (for example, customer support, HR, marketing, product) and giving them a concise briefing that explains what personal data is, what can go wrong, and when they should ask for help. A single, well‑targeted training session can prevent many simple mistakes. You may also have access to some learning platforms through your cyber insurer or other providers. Take a look at resources you already pay for to see if there are ways to incorporate them into a training program.

This is also a good time to test your incident response plan in a safe environment. Run at least one privacy tabletop exercise with a scenario that feels realistic for your organization. Include technical teams, legal, and a business representative a a minimum. If you plan to test a specific scenario that would benefit from other input, include those individuals as well. For example, if you think your biggest risk is a vendor breach, include procurement at the tabletop. If you think it's an employee getting spear phished, including an HR representative. You will quickly see where roles are unclear, where information gets stuck, and which decisions are hard. Capture these lessons in a short after‑action report with owners and deadlines assigned to remediate gaps.

By the end of Phase 2, your program should feel less like a series of disconnected tasks and more like a basic system where issues flow through recognizable paths, policies roughly match reality, and people know who to call when they’re not sure.

Phase 3 (Months 12–24): Mature, Measure, and Evidence

Once the basics are in place and functioning, the next year is about deepening and proving your program exists if third parties ask.

“Deepening” means strengthening the domains you’ve already touched. Your data inventory becomes more complete and more regularly updated. Your vendor oversight becomes more structured, which means you start tiering vendors by risk, reviewing security documentation for high‑risk providers, and aligning data deletion and retention across systems. Your incident response practice evolves as you refine your incident response plan based on real events or exercises, run additional tabletops that involve executives and more cross‑functional stakeholders, and add a simple decision log so that your choices are documented.

“Proving” means being able to show what you’re doing, not just describe it in a narrative. This is where the idea of an evidence library becomes valuable. Create a secure location (through an internal folder or governance tool) where you keep artifacts of your program. These would include current policies, screenshots of key controls, evidence of training completion, vendor security reviews, DSR metrics, privacy impact assessments, tabletop reports, and post‑incident summaries. Whenever someone does “privacy work,” ask, “What’s the evidence of this?” and put it in your library.

This period is also ideal for introducing a small set of metrics. You do not need a complex dashboard. Pick a handful of measures that genuinely show whether the program is working. Examples might include time to assemble an incident response team, number of high‑risk vendors without completed reviews, percentage of systems inventoried, median time to close DSRs, number of privacy‑related issues identified in product reviews, and completion rates for key trainings. Track these quarterly and look for improvement, not perfection.

As your program matures, your conversations with executives should evolve too. Instead of only surfacing issues when something goes wrong, be proactive. Once or twice a year, provide leadership with a brief, honest summary about what has improved, where your biggest risks are, what you are doing about them, and what support or investment you need. This rhythm keeps privacy from being seen solely as a cost center or a fire drill. If you work with outside counsel, consider having them help you generate these executive briefs to preserve privilege around what your team still considers gaps.

Finally, consider the emerging areas that matter for your business. If you are using machine learning or large language models, start adding some AI governance basic, such as an inventory of AI use cases, simple risk assessments for higher‑impact models, and guidance for staff on acceptable use. If you operate in jurisdictions with specific privacy audit or assessment requirements (such as California), begin aligning your evidence library and program design with what those audits will expect.

By the end of the two‑year horizon, you’re aiming for something modest but powerful, and that is a privacy program that is documented, repeatable, and credible, even if it is still evolving.

How to Keep Momentum Without Burning Out

Two years can feel like a long time. The risk is not that you suddenly won’t care about privacy but that other projects will crowd it out. Consider the following few principles to help keep the work manageable.

First, choose a cadence instead of relying on willpower. Monthly or quarterly working sessions for the privacy program owner and key partners are more effective than big annual pushes. Use those sessions to update the inventory, review metrics, prioritize improvements, assign owners, and set goals for the next period along with plans on how to execute.

Second, treat privacy improvements like product work. That means scoping them, planning them, and closing them. “We should improve vendor due diligence” is vague. “This quarter we will tier our top 30 vendors by risk and update our DPA template” is concrete. You will feel more progress when improvements are framed as discrete projects.

Third, be honest about tradeoffs and document decisions. There will be times when you decide not to tackle a particular improvement right away. Document that choice and why you made it. This keeps deferred work from vanishing and gives you a starting point when you revisit the risk later. It also provides evidence that you considered the project and the business reasoning or judgment for the deferral. It might seem counterintuitive, but being able to show a regulator or an auditor why you didn't do xyz is preferable to them assuming you just didn't notice the gap or put in no effort to consider it.

Fourth, reuse patterns. The same structures that you build for one domain, such as intake forms, checklists, decision logs, and SOP templates, can often be applied across domains. Don’t create bespoke documents each time when a shared pattern or reusable workflow will benefit your business repeatedly.

The Payoff is Resilience and Credibility

When you move from “we have a notice and an inbox” to “we have a living privacy program,” several things change inside your company.

Incidents become less chaotic, because roles are clearer and people have practiced engaging them. Regulators and auditors are easier to talk to, because you can point them to concrete evidence rather than scrambling to reconstruct what happened. Customers and partners see that you take their data seriously, not just because you say so, but because you can describe the machinery behind the scenes.

Most importantly, your own teams feel the difference. They know where to go with questions. They have templates and guidance instead of blank pages. They can build and ship with a more precise understanding of what’s allowed inside your company and what needs extra review and approval.

Privacy will never be “done” because laws evolve, technologies change, and your business grows, but a well‑built program gives you something far more valuable than a static checklist. It gives you a way to plan hard, respond fast, and learn always, on purpose, instead of by accident.