Privacy Compliance

Building Privacy Programs That Meet Regulatory Requirements

Privacy regulations impose comprehensive requirements on how organizations collect, use, store, and share personal information. The regulatory landscape continues to expand—GDPR, CCPA/CPRA, state privacy laws, and sector-specific regulations create overlapping obligations that require coordinated compliance approaches. This practice helps clients build privacy programs that meet applicable requirements while enabling legitimate business use of personal information.

Regulatory Landscape Assessment

Effective privacy compliance begins with understanding what regulations apply. Assessment examines where the organization operates and processes personal data, what categories of personal information are collected and processed, what processing activities occur and their purposes, which individuals' data is processed and their locations, and sector-specific regulations that may apply such as HIPAA, GLBA, or COPPA. Regulatory mapping identifies applicable requirements from this analysis. Many organizations face multiple overlapping regimes requiring coordinated compliance strategies.

Privacy Program Development

Sustainable compliance requires structured privacy programs rather than ad hoc responses to specific requirements. Program elements include governance structures establishing accountability and decision-making authority, policies and procedures documenting compliant practices, data inventories and mapping tracking what data exists and how it flows, training programs building awareness across the organization, vendor management addressing third-party data handling, and incident response procedures preparing for potential breaches. Program design should be proportionate to risk and regulatory exposure while enabling business operations.

Data Subject Rights Management

Privacy laws grant individuals rights over their personal information including access to know what data is held about them, deletion of personal information in many circumstances, correction of inaccurate information, portability to receive data in usable formats, and opt-out of sales or certain processing activities. Organizations must establish procedures to receive, verify, and fulfill rights requests within statutory timelines. Process design affects both compliance and operational efficiency. Technology solutions can streamline rights management at scale.

Notice and Consent Management

Privacy laws require transparency about data practices through privacy notices and often require consent for certain processing activities. Notice requirements specify what information must be disclosed and how. Consent requirements vary by jurisdiction and processing type—GDPR requires freely given, specific, informed consent while CCPA focuses on opt-out rights for sales. Managing consent across channels and jurisdictions requires systematic approaches. Consent management platforms can track permissions and preferences while supporting compliance documentation.

Vendor and Third-Party Management

Personal data shared with vendors and partners creates compliance obligations that extend beyond organizational boundaries. Data processing agreements establish contractual protections required by regulations. Vendor due diligence assesses third-party privacy and security practices. Ongoing monitoring verifies continued compliance. International data transfers require additional safeguards. Vendor management programs operationalize these requirements across supplier relationships.

Cross-Border Data Transfers

International data flows face restrictions under GDPR and other regulations. Transfer mechanisms include Standard Contractual Clauses, Binding Corporate Rules, and adequacy determinations. The evolving legal landscape for EU-US transfers requires ongoing attention. Transfer impact assessments evaluate adequacy of protections. Documentation requirements support compliance demonstration. Counsel helps clients structure compliant international data flows while monitoring legal developments.

Privacy Impact Assessments

Many regulations require privacy impact assessments for high-risk processing activities. PIAs evaluate necessity and proportionality of processing, identify and assess privacy risks, and document safeguards addressing identified risks. Assessment processes should integrate with product development and business operations. Documented assessments support accountability requirements and demonstrate compliance efforts.

Compliance Monitoring and Audit

Privacy programs require ongoing monitoring to ensure continued compliance. Internal audits assess program effectiveness and identify gaps. Metrics and reporting track compliance status. Regulatory developments require program updates. Documentation practices support accountability demonstrations. Regular review ensures programs remain current and effective as regulations evolve and organizational activities change.