How to Build a Privacy Program from Scratch (Governance, Inventory, Rights, Vendors)

Build Sequence

1. Governance: Appoint privacy lead / DPO where required; RACI; policy set
2. Inventory: Systems, categories, purposes, recipients, locations (mapping template)
3. Transparency & basis: Notices; lawful basis / consent records as applicable
4. Rights: Intake channels, verification, clocks (GDPR one month; CCPA 45 days + extension)
5. Vendors: Processor diligence, DPAs, sub-processor change control
6. Retention: Schedule + deletion evidence
7. Security: TOMs + monitoring via ThreatHawk where operational evidence matters
8. Assurance: Internal audit; consider ISO 27701

Programme Metrics

• Inventory coverage (% systems mapped)
• DSAR SLA attainment
• Vendor review currency
• Open high-risk DPIA actions

Frequently Asked Questions

Do startups need a full PIMS on day one?

Start with inventory, notices, rights intake, and vendor basics. Expand into ISO 27701 when buyers or regulators demand it.

Who owns the programme?

A named privacy lead or DPO (where legally required) with executive sponsorship.

Where does SIEM fit?

Security monitoring evidence for confidentiality/integrity and faster breach awareness — see privacy vs security.

Related Privacy Resources

PIA/DPIA · DPO as a service · CSA Privacy