Fractional Privacy Officer vs. Virtual Chief Information Security Officer: What is the difference?

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Fractional Privacy Officer vs. Virtual Chief Information Security Officer blog header

Privacy and security can be likened to the classic peanut butter and jelly sandwich combination. Just as peanut butter and jelly, each brings their unique flavors to create a well-loved snack, privacy and security serve distinct, yet complementary, roles in protecting data.

Privacy is akin to the jelly—sweet, nuanced, and about personal preference. Security, on the other hand, is like peanut butter—thick, protective, and robust, aiming to safeguard data from unauthorized access and breaches. While you can enjoy a sandwich with just peanut butter or just jelly, combining the two creates a more satisfying and comprehensive experience. Similarly, companies focused on privacy and security ensure that they are complying with privacy laws and protecting the data.

Today, more than ever, data privacy and information security are critical to an organization’s success. It ensures our organizations are safer and better able to conduct business. But having knowledge about data privacy and compliance, as well as cybersecurity is hardly enough. That is why there are specialized roles and jobs dedicated to these tasks.

However, these roles aren’t exactly like comparing apples and oranges – it’s more like apples to pears. In large companies, Chief Privacy Officers (CPO) lead the charge on data privacy, and a Chief Security Information Officer (CISO) is responsible for security. Not all companies need a full-time CPO or CISO. 

Enter the Fractional Privacy Officer (FPO) and Virtual Chief Information Security Officer (vCISO).

Often, thanks to the jargon involved, it’s really easy to mix up the roles. So, let’s back up for a second and look at what each of these individual roles entails.

What is a Fractional Privacy Officer?

An FPO provides your company with a knowledgeable, experienced data collection and privacy compliance officer – someone whose sole task is to understand data privacy and reduce risk to your company. And since this is a fractional position, they also bring a wealth of knowledge and experience from their current or prior work with other companies for less than a full-time hire. 

Hiring a full-time senior privacy executive is expensive, and that person often wants to avoid getting into the nitty gritty details that a company will need to do. Employing a junior person who is interested in doing the detailed work will not have the high-level strategic view that’s required to be successful. A company can instead hire an FPO who is willing to do the detailed work and provide the strategic lens.

Fractional Privacy Officers focus on data privacy and must be knowledgeable about security.  Since not all data is directly related to cybersecurity, an FPO can manage the privacy risk presented by third parties and vendors, understand how data is being used and collected, ensure proper disclosures are in place, determine the impact of new privacy regulations, and much more.

Fractional Privacy Officer Role and Responsibilities

Simply put, an FPO directs and implements data privacy and compliance efforts for your organization. And, thanks to the vast landscape of new and evolving privacy laws, this position requires diligence and regulatory know-how. 

For instance, the International Association of Privacy Professionals notes that there are 14 state privacy laws in the United States alone so far. Meanwhile, the number of global privacy laws is constantly increasing and evolving. The FPO diligently keeps tabs on privacy processes to ensure that your company complies with regulations, such as GDPR, CCPA, CPA, VCDPA, CTDPA, and UCPA, while staying informed of new and upcoming regulations as part of their risk assessment processes.

Beyond that, the FPO plays a pivotal role in crafting a strategy that aligns with your company’s business, technology, and compliance goals. While this may sound straightforward, entrusting your data privacy to someone lacking experience can be risky. With a qualified and attentive FPO, your organization can avoid potential fines, non-compliance lawsuits, PR nightmares, and, ultimately, lost profits.

A dedicated FPO can assist your company in creating a privacy program and provide support in various areas by:

  • Creating and/or updating data inventories & maintaining continuous compliance.
  • Maintaining & updating privacy notices & policies across digital platforms.
  • Enabling cookie consent banners & maintaining website scan audits.
  • Centrally managing & integrating consent with existing digital marketing platforms.
  • Automating privacy assessments to see the impact on your business.
  • Staying on top of new & existing privacy laws to manage compliance.
  • Automating consumer rights requests from intake to fulfillment.
  • Creating third-party risk assessments to manage vendors.
  • Designing and assisting with the implementation and testing of a data subject access / individual rights request process. 
  • Creating or updating privacy notices, information governance, and security policies. 
  • Serving as an External Data Protection Officer (DPO) – only for U.S.-based companies. 
  • Deploying an online-based questionnaire to one or multiple subject matter experts to assess compliance with privacy requirements. 
  • Creating and performing privacy impact assessments for new products or marketing campaigns. 
  • Evaluating compliance with digital marketing tools (e.g., analytics, advertising, email) by ensuring personal information is not being stored unnecessarily, data is anonymized, and only required data is captured. 
  • Reviewing your marketing agency to ensure their tools are privacy-compliant 
  • Analyzing and proposing any changes that need to be made for a business to appropriately target children (under 16 in many jurisdictions) 
  • Assisting with evaluating and implementing third-party privacy technology vendors such as assessments, data management, consent tools, reporting of processing activities, data security and more. 
  • Evaluating and strategizing new or existing products/services

What is a Virtual Chief Information Security Officer?

A Virtual CISO (vCISO) or Chief Virtual Information Security Officer specializes in overseeing and managing information security programs. Unlike the FPO, who zeros in on data privacy and compliance, a vCISO focuses on every operational application of information security, which includes securing an organization’s IT systems and the data that’s collected from these systems

Think of a vCISO as a cybersecurity gatekeeper who uses various tools, technology, and security controls to deter and/or prevent bad actors from gaining unauthorized access to sensitive information.

Whether it’s regular support, project-based assistance, or tackling specific IT or cybersecurity-related business goals, a vCISO adapts to your organization’s needs. The role is quite flexible, and just like an FPO, a VCISO can work in part-time or full-time capacities. 

Virtual Chief Information Security Officer (vCISO) Role and Responsibilities

The chief role of the vCISO is to establish and uphold your company’s cybersecurity program. A vCISO can either serve as a “lone ranger,” helping you build your cybersecurity team, and/or by overseeing a security team already in place.

VCISOs can also take on a leadership role, write and establish organizational security policies and procedures, complete cyber risk assessments on operational security, and share threat intelligence. Above all, a Virtual CISO provides advice and support in a crisis – such as a cyberattack or a data breach.

For the most part, in any capacity, vCISOs typically:

  • Develop and implement processes that help detect, mitigate, and recover from cyber attacks
  • Develop and implement ongoing cybersecurity training for staff
  • Implement and manage cyber risk and governance
  • Constantly evaluate the cybersecurity landscape for posturing against threats
  • Secure the organization’s cyber and technological assets
  • Educate business leaders on the topics of technology risk and cybersecurity
  • Provide reporting to leadership on cybersecurity activities

Protecting Your Organization

Both roles – FPO and vCISO – require specialized knowledge and access to coordinated technology. Sometimes, they even use the same technologies! And, while their daily tasks both help to protect your company, they also have slightly different goals.

For instance, an FPO can help your company expertly handle cookie consent or perform data privacy assessments. They can also proactively conduct third-party risk assessments to minimize risk before it becomes problematic. The main job of an FPO is to ensure that you maintain compliance with all applicable privacy regulations and/or laws and are using data in accordance with company values and customer expectations.

Meanwhile, a vCISO can help you develop and implement security processes and systems to prevent, detect, mitigate, and recover from cyberattacks or data breaches.  A Virtual CISO does this by building and driving a cybersecurity posture, strategy, and framework – with initiatives to secure your cyber and technology assets. A vCISO can also help develop training for your staff or help you hire staff that meets those standards — just like in-house chief information security officers.

Advantages of employing a Fractional Privacy Officer and Virtual CISO

Now, back to the peanut butter and jelly. Putting it all together, the FPOs and vCISO should have a symbiotic relationship. It’s not about the privacy officer versus the security officer. They aren’t fighting each other for dominance. They are working together to lift each other up, just like adding jelly to that thick, gooey peanut butter to make a delicious sandwich. 

But like most symbiotic relationships, it’s complicated, requiring a delicate balance and knowledge of who does what.

Think of privacy and security as a treasure-filled garden. Installing a solid wooden fence significantly boosts your security, making it hard for any animal or hungry neighbor to steal your delicious treats. Installing that fence gives you more privacy, ensuring that your stash remains hidden from prying eyes.

Privacy isn’t foolproof, though. Just as someone might peek over your garden fence and catch you downing all the raspberries after a two-hour-long Zoom lecture, you need an extra layer of protection. Even with that fence, you’ll need to install tall, charming trellises or thick bushes to safeguard your privacy further.

Incorporating motion sensors into your garden? Presto! You’ve just added another privacy control. Effective data protection programs intertwine with various security measures, creating a fortress with layers upon layers of security and privacy features. The FPO and vCISO act as the guardians.

So, when it comes to the advantages of hiring an FPO and a vCISO, both provide a combination of technical knowledge and corporate governance with the flexibility to tackle current and emerging information technology, security, and privacy threats. 

Just like an FPO, working with a virtual CISO allows you to access highly qualified and experienced security expertise – on an as-needed basis for your cybersecurity strategy.

Is an FPO or vCISO right for you?

How do you know if a virtual CISO service or FPO is the right choice for you? Well, if you are: 

  • A business that doesn’t have the volume of privacy and security needs or the budget to hire a full-time internal CISO or FPO
  • A smaller organization with relatively simple cybersecurity and/or data privacy/compliance needs

A vCISO or FPO may offer the perfect choice.

FPOs and vCISOs grow with you

Like everything else in business, cybersecurity and data privacy constantly evolve. An FPO or a vCISO can help your organization navigate this changing landscape successfully.

Developments in Artificial Intelligence are changing the landscape in all areas of business. A virtual CISO or FPO will be ready to tackle AI developments – and how these can bolster your security posture and privacy. 

Virtual CISO and FPO roles can help you shift to Zero Trust Architecture, built on a “never trust, always verify” principle. This methodology can simplify your framework while enabling greater visibility and control over the users and traffic in an environment.

Recruitment and retention in cybersecurity and data privacy can be difficult for organizations. An FPO and a vCISO can help you set standards, hire staff, and guide your recruitment policies so that you meet your privacy and/or security goals.

Think you need a Fractional Privacy Officer? Let’s Talk!

We know it’s not easy to run a business. That’s why we’re here to help! If your company faces privacy questions, we can provide answers. At Red Clover Advisors, we are experts at maintaining data privacy and compliance. 

No matter what your organization does, Red Clover Advisors is ready for you. From startups to Fortune 500 companies, we have a proven record of partnering with organizations to provide data privacy and compliance assurance – including our Fractional Privacy Officer (FPO) service offering. 

We can refine, update, or build your privacy program. Our certified privacy professionals (CIPP/US/E/A) integrate all the practitioner-level knowledge required to deliver sustainable privacy program outcomes.

To learn more, schedule a call with Red Clover Advisors today!