The modern corporate privacy program, especially within mid-size enterprises, has inadvertently evolved into a major source of operational complexity, frustration and friction, often disproportionate to the actual regulatory risk it seeks to mitigate. Instead of being designed as a streamlined risk management function, programs frequently become bloated, slow, with checklist-driven mandates built to satisfy the compliance demands of every fragmented state law individuallyand equally. This approach leads to “checklist paralysis,” diverting excessive time and budget towards documentation and reviews rather than focusing resources on the small subset of truly high-risk, sensitive data—the company’s “crown jewels.” The result is a system that is overly expensive, strategically inflexible that creates tension between the mission-oriented departments (development, sales, delivery) and the control-oriented groups (risk, compliance, legal).
To combat this complexity, organizations must pivot from a purely centralized compliance model to a hybrid that includes distributed, risk-balanced privacy program execution. This alternative design requires strategically moving certain privacy activities out of a central department and embedding them within the business functions that create, gather, storeand process data.
The foundation of this distributed model rests on three pillars of activity across the organization:
- Strategic Governance (Central Team): The central function shrinks to focus only on program stewardship, high-level policy, external regulatory change monitoring, risk modeling, and overall accountability. It defines the “what” and “why.”
- Embedded Privacy-by-Design (Engineering/Product): Department-level individuals are trained to own the initial privacy decisions (with consultation where necessary). They are responsible for implementing data protection, data minimization and purpose limitation controls at the system design level, making the program proactive rather than reactive. This operationalizes the core tenets of the principles-based framework directly into the creation of new products and services.
- Automated Execution (Operations/IT): This is where Privacy Management Platforms (PMPs) become the essential enabler of the right-sized program. Cloud-based PMPs distribute the workload for high-volume, repetitive, and resource-intensive tasks without distributing the risk.
By leveraging these platforms, a company can automate the most common compliance burdens: maintaining automated data inventories, standardizing and deploying consent banners, and managing the workflow for Data Subject Access Requests (DSARs). This automation drastically reduces the risk and the need for expensive, manual labor—the biggest driver of complexity and cost—allowing the distributed staff to focus on genuine innovation and high-value risk mitigation.
In conclusion, right-sizing a privacy program requires a strategic trade-off: trading centralized control for decentralized accountability, and trading manual compliance for automated execution. This approach removes unnecessary friction, lowers operational costs, and transforms privacy from a bureaucratic hindrance into a sustainable, competitive edge that fosters enduring customer trust.
J. Howard, CDO & CPO 