Map Data Flows First
Build an initial data inventory covering collection points, storage locations, vendors, internal access roles, and retention patterns. Keep it simple enough to maintain and detailed enough to support decisions.
Focus first on high-impact data categories and assign an internal owner to keep the map current.
Align Disclosures and Controls
Privacy notices should match actual practices. Misalignment between disclosures and behavior is a common source of legal and reputational risk.
Create vendor intake controls with data processing terms, security checks, and renewal review cycles.
Prepare for Requests and Incidents
Define intake channels, identity verification, response timelines, and escalation paths for data rights requests.
For incidents, create a response matrix with named roles, decision rights, and communication chains. Tabletop drills surface weaknesses before real events occur.
Key takeaways
- Start with data visibility and ownership.
- Ensure disclosures match operational reality.
- Treat vendor governance as a core privacy control.
- Create repeatable workflows for data rights and incidents.
General information only. Privacy obligations vary by jurisdiction, sector, and specific data practices.