Privacy Program Development and Management

Program design and build

We design the program around your size and structure rather than an idealised org chart. For a company with no dedicated privacy staff, that means a small number of clear obligations attached to existing roles. For a company with a privacy team, it means charter, authority and reporting lines that let the team make decisions stick.

• Governance structure with named accountability and a defined reporting line to leadership.
• Policy set: internal privacy policy, retention schedule, rights handling, vendor management, incident escalation.
• Control mapping that shows which single control satisfies obligations under more than one regime.
• Metrics leadership can actually read, tied to risk and to statutory deadlines rather than to activity counts.

Data mapping

Nearly every privacy failure traces back to data no one remembered holding. Mapping is the foundation the rest of the program stands on, and it is worth doing at a level of detail you can maintain. We build an inventory at system level, keyed to purpose, legal basis, retention, recipients and transfers, and we design it so updating it is part of shipping software rather than an annual project.

• System and process inventory covering production systems, SaaS tools and shadow IT.
• Data flows, including onward disclosures, sub-processors and cross-border transfers.
• Records of processing that satisfy Article 30 rather than approximating it.
• A retention schedule with defined disposal, and a route to apply it to backups and archives.
• Maintenance triggers tied to procurement, new features and new markets.

DPIAs and PIAs

Assessments are where a privacy program either earns its place or becomes paperwork. Done properly, an assessment is a design conversation held early enough to change the design. We provide a method, a threshold test that tells teams when an assessment is genuinely required, and enough facilitation that the first several are done to standard.

• Screening questions that route most projects through in minutes and flag the ones that need real analysis.
• Facilitated DPIAs for high-risk processing, including profiling, monitoring, sensitive categories and large-scale use.
• CPRA and state-law risk assessments prepared to the form regulators are asking for.
• Mitigations recorded with owners and dates, so an assessment produces changes rather than observations.

Ongoing management

Many companies need a privacy function but not a full-time hire. We can hold the program on a retained basis: chairing the review cycle, handling escalations, keeping the inventory and assessments current, briefing the board, and standing in front of customer security reviews and diligence questionnaires.