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In the digital age, the paradigm of privacy compliance has transitioned through a significant metamorphosis. Traditionally anchored in legal and compliance departments, the guardianship of data privacy and The evolution of data stewardship is experiencing a tectonic shift towards various other segments of an organisation, such as IT, data security, customer service, and even marketing. This diffusion of responsibility, while fostering a broad-based engagement with privacy matters, also raises the spectre of potential conflicts of interest.


Privacy by Design

The concept of ‘Privacy by Design’ is a testament to the evolution of privacy as a core organisational function. It demands that privacy is not an afterthought but a foundational principle integrated into every layer of project development. A historical perspective tells us that retrofitting privacy safeguards into existing systems is cost-efficient and operationally disruptive. Privacy by Design, when owned by a dedicated data privacy function, ensures that products or services are engineered with privacy as a cornerstone, thus aligning with stringent global data protection regulations and reinforcing consumer trust.


Data Governance

Data governance is the compass that guides the management of data assets within an organisation. A specialised privacy function is the navigator, ensuring the alignment of data handling practices with privacy laws and ethical standards. It establishes clear policies on data access, quality, and lifecycle, mitigating risks of data breaches or non-compliance. The history of data privacy reveals that decentralised data governance can lead to ambiguous accountability, and an independent function is an antidote to this predicament.


Cross-Department Involvement in Building an Optimised Data Privacy Tech Stack

The convergence of technology with data privacy has necessitated the creation of an optimised privacy tech stack. Cross-departmental involvement is crucial; however, it requires harmonised orchestration to prevent conflicts of interest. For instance, while IT departments focus on the operational aspects of data security, the marketing department’s enthusiasm for data-driven strategies could overlook privacy implications. An independent privacy function ensures a balanced approach to vendor selection and tech stack optimisation, embodying protection and performance.

Now, let us delineate a three-step plan for reinforcing the organisational structure for Data Privacy.

1: Organisational Structure for Data Privacy

Establishing a robust organisational framework for privacy involves delineating clear lines of privacy ownership. Creating a centralised privacy function with direct reporting to the upper echelons of management—such as a Chief Privacy Officer—ensures independence and adequate authority to implement privacy strategies effectively.

2: Acquisition of Skilled Privacy Professionals or Outsourcing

The complexity of global privacy laws requires adept professionals who can navigate the nuances of compliance. Organisations must either cultivate in-house expertise or engage with seasoned privacy consultancies to fill this critical capability gap. The latter often provides extensive experience across jurisdictions and industries, contributing to a more robust privacy posture.

3: Allocating a Functional Budget for Data Privacy

Investing in privacy is not just a regulatory mandate but a business imperative. Organisations must allocate a dedicated budget for privacy functions, encompassing technology investments, training, and compliance activities. A strategic financial commitment can fortify an organisation’s reputation and consumer confidence.



As we embark on this series, examining five paramount challenges for data privacy in 2023, it’s evident that building a resilient, independent privacy function is not merely a compliance exercise but a strategic business advantage. Companies that pioneer this approach will not only navigate the regulatory landscape with agility but will also engender unwavering trust from their customers—translating privacy into a competitive differentiator in the digital economy.

In the following articles, we shall delve deeper into each challenge, outlining pragmatic solutions and foresight that could shape the future of data privacy. Stay tuned.