7 Steps Towards a Strong Data Privacy Program

Batja Huisman
Batja Huisman
Apr 26, 2022
min read
7 Steps Towards a Strong Data Privacy Program

**Updated March 2023**

The relationship between companies and data privacy practices can be a bit complicated. There are many processes, stakeholders, and risks to consider. These puzzle pieces must all come together to form one coherent flow, indicating the need for a detailed plan if a company hopes to put together a strong data privacy program.

When companies fail to create a comprehensive data privacy program that covers the handling of fundamental data rights like access and deletion, they risk damaging user trust along with facing fines and other brand repercussions. A recent survey shows that more than half of US social media users will ignore ads if the company behind them doesn’t protect their data privacy. 

Building and implementing a data privacy strategy will simplify compliance tasks like dealing with requests from data subjects and completing RoPA reports and DPIAs. 

Once you know which data privacy regulations you need to comply with and the corresponding legal obligations, here are seven steps to help you build a successful data privacy program.

Workflow Stages and Needs

Step 1: Training

This stage is internal and focuses on raising awareness among stakeholders across the organization. Making data privacy a priority requires input and empowerment from executives, which means privacy professionals need to be ready to explain why a strong data privacy program is necessary beyond the compliance checkbox itself.

Once you secure management’s backing, now you’ll need to train everyone in the organization. So many teams and roles are exposed to data privacy requests and private information in general that companies must ensure that multiple departments beyond Legal and Compliance understand what data privacy is all about, how important it is to take it seriously, and each department’s role in managing compliance and data protection.

Companies should create privacy plans for each department tailored to the employees’ level of expertise and required involvement. Multiple teams are in charge of forming such strategies, including:

  • Learning and Development teams to build training sessions.
  • Legal teams to guide and instruct teams.
  • Content pros to offer support for documentation needs.
  • Compliance advisors to help guide all these processes.

The result should include:

  • Regular training sessions.
  • Relevant materials that are available and regularly updated.
  • Periodic reviews to ensure that the team understands the initiative.

Step 2: Policies and Guidelines

This customer-facing step includes everything participants outside the business need to know about its data privacy stance. The process consists of creating a clear privacy policy, any request forms and guidelines customers might need, and other relevant materials. 

Companies should communicate their data privacy values and guidelines in a transparent and creative manner to customers to demonstrate their approach to data privacy. When it comes to data request forms and internal templates, this is also a matter of convenience and customer service. In addition to content professionals, the step involves Legal and Compliance teams and Customer Support representatives to make sure things are handled from a legal and compliance perspective, as well as a customer experience point of view. 

Step 3: Take inventory with Data Mapping

This is a crucial step that many companies have historically skipped because data mapping is so hard to do. Today’s data flows have grown exponentially, and organizations won’t be able to meet data compliance requirements reliably without a full overview of their data. 

While data mapping itself is not a GDPR or CCPA requirement, it applies to DSR handling, consent management, and other specific data regulation necessities like RoPA reports and impact assessments. 

That's why companies need strong data mapping capabilities. The goal is to build a data-oriented structure using innovative data mapping technology so privacy professionals can reap invaluable data insights from a more accurate picture of an organization’s data as well as minimize reliance on engineering and IT to routinely track down where specific data resides within the organization.

Step 4: Design 

It’s not enough to manage data after it is gathered and processed by the company. Privacy-by-design principles, which are written directly into the GDPR, help companies ensure that when users put their product or service to use, the experience is respectful of user boundaries and keeps private information secure.  

For this part of the process, Product Managers and UX experts with a background in data privacy (which may have been acquired during the training stage) work to build a more privacy-oriented and less invasive product. This includes only asking for relevant data, offering explanations regarding the usage of said data, giving users an easy path towards withdrawal, and more. 

Step 5: Request Management 

After establishing the foundation for subject request submission, companies need a system that can handle the potential flood of requests coming from users. If the data mapping step was performed successfully, combining it with this step should offer sufficient tools for managing requests as part of the data privacy program. Doubly so if an organization uses a tool that has integrations with popular SaaS tools so request handling can be automated.

Companies also need an organized portal that collects all data requests and offers information regarding their status, time for completion, appropriate steps, and more. A dashboard should be designed in correlation with the company’s legal and compliance guidelines, which requires the involvement of these teams. Customer Support representatives work closely with the dashboard and communicate any delays or feedback to users, another way that various members of an organization engage with a data privacy program on a day-to-day basis.

Step 6: Implementation 

At this point, companies should have the necessary information to handle any DSR request on a practical note, which is what this step is all about. IT teams are in charge of collecting and deleting data as requested based on the company’s guidelines and the information presented on the dashboard if no integration is present. 

This step is mainly technical, but communicating it to other teams and staying in touch with Customer Service representatives is crucial. 

Step 7: Completion and Documentation 

For data audit purposes and future requests, it’s essential to document the process thoroughly. You might say that this step takes place alongside all others. The results are communicated to the user, letting them know that their data was deleted and offering any necessary explanation regarding the impact it might have on their future interaction with the product. 

This step involves Compliance teams and Customer Support representatives, as well as specific stakeholders in charge of informing all other teams that took part in the workflow. 

A strong data privacy program is worth the effort

It’s clear to see that a data privacy program is an all-hands-on-deck effort. Companies can adjust the workflow to fit their specific needs and nature, but these basic steps should offer a proper foundation no matter how big a business is. 

With a detailed, structured process backed by the right data privacy tools, companies minimize the risk of skipping necessary parts and paying the price in brand reputation damage and legal fines.