An overview of the
Data Privacy Maturity Model
Data privacy is evolving from a regulatory compliance initiative to a
customer trust imperative. The primary business value of early-stage Stage 4
data privacy programs is mitigating risk by ensuring compliance with Scaled
external regulation and internal policy. As programs mature, data
Stage 3
privacy also becomes a strategic driver of customer trust. Strategic
Business Value
When an individual trusts that a company is using their data
Stage 2
responsibly, they are willing to share more data, which enables the Proactive te risk
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company to increase its customer engagement, loyalty, and lifetime (m
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value. This virtuous cycle of earning, retaining, and reinforcing m u
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Stage 1 Co st
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customer trust to unlock the value of data is the strategic goal of a Reactive
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mature data privacy program. The expanding footprint of regulation, Cu
the urgency of building first-party datasets, and the responsibility
of ethically managing data-hungry AI models reinforce the business
criticality of getting data privacy right.
Program Maturity
Here is a closer look at how to use the Data Privacy Maturity Model to
expand the business value of a data privacy program from compliance to customer trust.
Stage 1: Reactive
At the beginning, companies often don’t have established data privacy programs and tend to address new regulations reactively as
they emerge. Their data privacy efforts are primarily tracked via spreadsheets, which are not scalable. Data privacy is generally not
prioritized, with programs addressing only baseline requirements such as cookie compliance. This ad-hoc and manual method of
managing data privacy is inefficient.
Stage 2: Proactive
In Stage 2, companies begin using software to establish a structured data privacy program to comply proactively with regulations. Data
privacy becomes a key duty of top legal or compliance officers, who oversee small teams. Companies gain visibility into their data, better
assess third-party risk, and start to integrate basic AI oversight. Still, the primary goal of these programs is to ensure compliance.
Stage 3: Strategic
Stage 3 is a major shift. Processes are optimized and there is shared accountability for data privacy across the business, not only in
the legal or compliance function. A strategic framework is in place to anticipate future regulatory requirements. Most importantly,
responsible acquisition and use of first-party data is viewed as central to customer trust. The company also actively monitors and
addresses data privacy violations, establishes and validates data controls, and mitigates the risk of sensitive AI training datasets.
Stage 4: Scaled
In Stage 4, data privacy becomes a key part of decision-making and business strategy. Companies use customer data to enhance
products and deepen relationships, benefiting from advanced analytics and AI. Datasets are future-proofed, with risk-informed data
sharing. Processes are optimized, and policies are defined centrally, with reliable decentralized execution. AI governance programs
bring issues to the surface early in the development process to support innovation and fast time-to-market. The data privacy program
becomes central to unlocking the business value of customer data.
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