The Orchestra of Privacy Management: Lawmakers, Technology & the FPO
You can’t have an orchestra without a conductor, and you can’t have a conductor without the instruments. And none of it works without music to play.
The same can be said when it comes to privacy management.
The GDPR, CCPA and other global privacy laws operate as an orchestra. The lawmaker is the composer, the conductor is the Fractional Privacy Officer (FPO), and the orchestra is the technology to implement compliance.
And just like an orchestra needs all parts – composer, conductor, and instruments – to operate, so does privacy management. You can’t have one without the other.
Being a conductor – in this case the FPO – for an orchestra isn’t a gesture to cue the music and walk away. The FPO and the technology go hand-in-hand to create a unified implementation force. It’s directionally sound and delivers a satisfying result.
Breaking Down The Ensemble: The Conductor
A conductor (privacy consultant or FPO) is essentially the interpreter for the composer (lawmakers).
From setting the tempo to bringing the whole production to life, the FPO directs and implements the day-to-day execution of privacy compliance across global privacy laws for the organization.
This expert also helps you create a strategy for what technology your company requires and how to integrate each piece of technology to complement the others, much like instruments in an orchestra.
Outsourcing your privacy program management can save you time, money, and lots of headaches.
The compliance measures you established for the CCPA aren’t enough to support ongoing privacy issues and additions to the laws that inevitably arise. Checking the box once on compliance implementation isn’t going to fly with lawmakers. In fact, most require consistent and proactive monitoring.
Although many companies assign this role internally, this leaves too much room for error.
You wouldn’t see the expert violinist directing the orchestra during the symphony. So it’s not wise to pull a talented team lead into an arena they’re not trained to handle
Cue the FPO.
Timing and organization is vital for building a privacy management program. It’s not an easy task without the right technology. And it’s even more challenging when you don’t have any at all.
The FPO is responsible for the entire privacy ensemble:
- Interpreting & monitoring privacy laws and industry updates to maintain compliance
- Connecting and building a privacy program
- Listening to maintain, report, and assess potential risks
Those are just some of the key aspects the Fractional Privacy Officer manages for a privacy program. But this privacy guru can’t implement a privacy strategy without the right tools.
Every meastro needs his or her instruments, after all.
The Instruments of Privacy Technology
With 80+ countries having passed privacy laws, using the right kind of solutions to help automate, monitor, and implement compliance is key to finding the perfect pitch. Once you’ve mastered getting GDPR or CCPA compliance up and running, building a scalable privacy program becomes an additional layer to the foundation you’ve already built.
The instruments become the privacy technology the conductor needs to create a sustainable privacy management program.
Leveraging a full suite of solutions for compliance with GDPR, CCPA & new upcoming regulations will enable the FPO to fulfill their duties. Without both you risk data breaches, non-compliance suits, PR nightmares, and even worse, lost profits.
There’s one person who manages the technology to avoid such risks.
A key role of the FPO is to support implementation of privacy management technology. The complex landscape of privacy should be maintained by a proactive individual who understands the inner workings of the regulations, best practices, can measure effectiveness and mitigate risk before it even happens.
Privacy technology instruments are used by the FPO to:
- Streamline data inventories & maintain continuous compliance
- Maintain & update privacy notices & policies across digital platforms
- Enable cookie consent banners & maintain website scan audits
- Centrally manage & integrate consent with existing digital marketing platforms
- Automate privacy assessments to see the impact on your business
- Stay on top of new & existing privacy laws to manage compliance
- Automate consumer rights requests from intake to fulfillment
- Creating third-party risk assessments to manage vendors
- Evaluate and strategize for new or existing products/services
- Train team members on implementation & regulations
How would these tools be used in practice with the FPO as the conductor?
Creating & Mitigating Third-Party Risk Assessments
Today, there are many tools at the FPO’s disposal to build an ongoing privacy program.
From cookie consent to performing third-party assessments, to overseeing compliance and technology, an expert can build a strong privacy program for any company.
Third-party risk assessments are a proactive way for an expert to minimize risk before it actually becomes a red flag. The FPO can assess vendors with automated assessments to ensure they aren’t a risk for the company.
Review Existing Data Inventories & Update Them with any New Changes
Managing data inventories represents a critical component of compliance.
Data inventories help companies understand the data they have from start to finish. It means you understand what specific pieces of information you’ve collected about each person and vendor, and exactly where each of those pieces of information are stored.
Using an Excel spreadsheet to a Google Doc to create a data inventory just won’t cut it anymore. There’s a massive amount of data that needs to be mapped and updated regularly. And there’s no way to create advanced reports.
The FPO manages this entire process and the technology that automates it.
This person pinpoints what data you have, how it’s being used, and where it’s stored so the information entered is accurate, business purposes are approved and allowed per privacy regulations, and policies and individual rights processes are constructed accurately.
Managing an Integrated Digital Marketing Compliance Program
Leveraging a unified tool for consumer requests, cookie compliance, policies & notices and consent management can be a confusing and challenging task for your company's marketing team to fully manage. But if anything, creating a strong digital marketing compliance program is vital to creating personalized experiences for prospects and customers.
The laws and regulations are the least of your marketing team’s worries.
They have quotas to meet with what they think is a marketable database to reach those goals. That’s where a FPO would act as the expert to centrally implement preferences and consent across all marketing platforms.
The danger here is thinking only using technology without an FPO will get the job done.
You still need the expert to train your team to use the technology. You need a person to safeguard what’s being captured is the right information.
An orchestra without a conductor – without someone to teach the music and ensure it’s being played correctly – is just a jumbled mess of sound. It doesn’t work, and neither does privacy technology without an FPO.
The FPO would use his or her knowledge of the regulations to help your marketing team implement the right consent questions and policy notices necessary to collect data. The use of technology such as cookie banners and preference management pages would then be used to create a single source of truth for marketing consent.
The combination of the privacy expert and the technology are vital to implementing the needs of your team while building a scalable program.
It takes the worry out of the hands of an individual whose day to day job isn’t privacy.
Again, you wouldn’t ask your star instrumentalist to lead the orchestra. Nor would you expect that person to understand anything but his or her own parts of the composition.
You can’t do the same thing with your marketing team, technology, and privacy management.
Conclusion: The Complete Privacy Management Orchestra
You need both the FPO and privacy management technology to make the orchestra of privacy compliance function. You can’t have one without the other. They’re both essential for building a strong privacy program.
Both will create and maintain a strong foundation for GDPR, CCPA and any new privacy regulations for you to handle.
Without a designated individual to maintain the different components of technology, assigning an employee or letting the software run its course leaves room for a reactionary response for when something goes wrong.
You need an expert in place who knows how to interpret the language, implement the technology, and can play the balancing act that lets your organization preserve trust. The role of the FPO is to navigate the privacy landscape for your company, understand the entire landscape, and determine a plan to carefully handle your data.
Much like how a conductor uses his or her baton to direct the whole ensemble, creating a process that can be properly implemented by an FPO establishes the necessary automation and reporting you need to operate around each framework.
The FPO and technology work as one whole unit building a solid foundation. When all of the parts of the orchestra are working together it creates a beautiful sound.
Cue the music.
FPO FAQ
If you’re not sure if you need a Fractional Privacy Officer or not, you’re not alone. Most companies ask themselves these questions to determine if it’s a good fit:
- Do we have the knowledge to deal with complex privacy regulations?
- Can we afford a full-time privacy officer?
- Do we have someone who can address privacy concerns as we grow and develop new products?
- Do we have a strategic data privacy mentor?
- Do we have someone who can keep tabs on what has to be done for privacy compliance?
If you answered no to any of these questions, a Fractional Privacy Officer would be a wise addition to your team. And if you’re still not sure what a Fractional Privacy Officer does or if it’s right for you, our team of experts can help you decide.
