What if kids never had to take a test in school?
It could be great, maybe. For some students, testing can be stressful and doesn’t indicate their true aptitude or comprehension of a topic.
Overall, school testing helps ensure that our children develop the skills they need to learn, grow, and thrive. If we never gave tests, it could become more difficult to determine if a child needs extra help or resources.
Your data privacy program is like that child. Similar to how schools test young students for insight into their strengths and areas for improvement, regular review and evaluation are critical to a data privacy program that meets the mark.
To create a program that benefits your business, you’ll achieve the best results when you regularly measure your privacy program performance for vulnerabilities or opportunities—meaning it’s time to study your metrics.
Understanding privacy metrics
There are several ways to assess your privacy program’s performance. The two major camps are counting metrics and outcome metrics:
- Counting metrics are activity-based. These metrics track the volume of privacy-related activities, including:
- How many assessments you complete
- How many data subject requests you process
- How long it takes you to process requests
- How many privacy incidents you respond to in a certain period
- Outcome metrics are impact-based. Impact-based metrics focus on the actual impact of your privacy efforts, such as:
- Training outcomes, like a reduction in phishing email clicks
- Increase in early privacy impact assessments (PIAs)
- Fewer last-minute project scrambles due to early privacy involvement
Both types of metrics have their advantages. Counting metrics may provide more immediate demonstrable results, while outcome metrics may take more follow-up and analysis.
However, activity-based metrics aren’t always the best measure of a privacy program.
To understand the overall health of your privacy program, impact-based metrics can better analyze your program’s strengths and weaknesses. For example, suppose your employee training program has a 97% completion rate, but you don’t see a reduction in phishing email attacks. This may indicate an issue with your training format or content.
To get the fullest picture of your privacy program, it’s best to include both types of metrics in your analysis. It should also identify which metrics are leading and lagging indicators.
Categories of privacy metrics
As a privacy industry standard, there are seven main categories of privacy metrics. Different businesses may want to focus on certain categories over others, depending on their resources and business model. The categories are:
- Individual rights: How well does your business achieve benchmarks for individual rights issues, like consumer consent, data subject requests, and privacy incidents?
- Metrics to look at:
- Average time to respond to data subject access requests
- Percentage of requests fulfilled within legal deadlines
- Number of privacy complaints received and resolved
- Metrics to look at:
- Training and awareness: How extensive is your cross-organizational knowledge or the effectiveness of employee privacy training?
- Metrics to look at:
- Percentage of employees who completed privacy training
- Scores on post-training assessments
- Reduction in privacy-related incidents after training
- Metrics to look at:
- Commercial: How well do you meet expectations for third-party and vendor compliance, data processing agreements, and supply chain evaluations, and how well do you adapt to new technologies as needed?
- Metrics to look at:
- Percentage of vendors assessed for privacy compliance
- Number of data processing agreements updated annually
- Time to integrate privacy requirements into new technologies
- Metrics to look at:
- Accountability: Are you following your privacy policies and best practices? Do you complete PIAs and regularly review your data privacy programs and policies?
- Metrics to look at:
- Number of privacy impact assessments completed
- Frequency of privacy policy reviews and updates
- Percentage of projects that involved privacy team from inception
- Metrics to look at:
- Privacy stewards: How do you implement and manage privacy across your company? Do you leverage privacy champions? Are some business units more prone to privacy incidents than others?
- Metrics to look at:
- Number of active privacy champions across departments
- Frequency of privacy steering committee meetings
- Privacy incident rates by business unit
- Metrics to look at:
- Compliance/regulatory: How well do you comply with data privacy laws and upcoming regulations? What is your risk exposure? Have you accounted for privacy laws that will come into effect in the next two years?
- Metrics to look at:
- Number of regulatory inquiries or audits
- Time spent on compliance activities
- Percentage of compliance with each applicable regulation
- Metrics to look at:
- Marketing: How many marketing opt-outs have you received and processed? How quickly do you process requests? How do your website cookie banners function? How accurate is your data?
- Opt-out rates for marketing communications
- Cookie banner acceptance rates
- Data accuracy rates in marketing databases
Now that we have a laundry list of privacy categories, we arrive at an important question.
How do you line up privacy metrics and business goals?
Not every business has the same needs. A single-person LLC may not need to focus on training and awareness, but it will need to work on its data privacy program for its marketing and website.
Essentially, your privacy metrics should reflect your company’s core business values.
Need some ideas?
- If customer experience is central to your business model, you may skew toward metrics like email unsubscribes, the number of privacy complaints received and time to resolution, or customer satisfaction scores related to data handling practices.
- If your business focuses on being a trusted government contractor for your state, then maintaining scrupulous regulatory compliance and having squeaky-clean vendor management processes will be a big focus for qualifying for work.
- If you’re looking to grow and expand your business into new markets, it can benefit your public relations campaign to demonstrate that you already comply with their data privacy regulations (especially if newer laws like the Washington My Health My Data Act or the Utah AI Policy Act are relevant to your business).
Aligning your privacy program with your business values isn’t just for the sake of symmetry, though. Consumers increasingly consider both privacy practices and corporate values when deciding who to do business with, with 81% of users believing how a company treats their personal data is indicative of how it views them as a customers.
What do your privacy metrics tell you from a business POV?
While it always feels great to get a gold star, privacy metrics aren’t just for show. Privacy metrics can help judge:
- Efficiency and cost savings: How much time and money are you saving through streamlining or automating data privacy processes?
- Improved customer (and employee) satisfaction: How do your privacy efforts impact customer trust or satisfaction? What about your employees’ trust in their leadership team?
- Decreased incidents and compliance risks: Is your legal team sleeping better at night? Can you demonstrate a reduction in privacy incidents and their impact on compliance risk?
- Increased employee awareness: How educated are your employees regarding data privacy? Has it led to any new initiatives or changes?
If the results are overwhelmingly positive, great!
On the other hand, if these metrics show improvement, then just knowing those opportunities can be a game changer. You can improve your business operations and even gain a competitive edge.
2025 Privacy Checklist
Check out our Privacy Checklist for tips and practical guidance to establish a sustainable compliance program.
How to build a privacy program that fits your business
As your business grows and the world changes, even a privacy program that worked perfectly for you last year may require updates to keep it working as intended. Continuous privacy program evaluation and improvement is essential to your long-term business success.
So, review your privacy program regularly. Consider how it can align with your broader business goals today and in the future, and consider how it can become your competitive advantage.
If your privacy program isn’t working for you, contact us to learn more about how you can build and effectively measure your privacy program.