These Are the Privacy Controls Every Organization Needs

Data fuels smarter decisions, sparks innovation and strengthens stakeholder trust. Yet, it’s an asset you rarely find on the balance sheet and its financial value can be underrepresented. This value depends on accuracy, accessibility and – above all – security. 

As organizations grow more data-reliant and regulations tighten, protecting it is non-negotiable – whether it’s customer, employee, vendor or operational data. The good news? This doesn’t always require a dedicated team. Simple, effective privacy controls can dramatically reduce risk and ensure it remains an asset – not a liability.

Understanding Your Data: The Foundation of Effective Protection

Effective protection starts with understanding your data. Ask:

1. What data types do we collect, store and share?
2. Who uses it and for what business decisions? 
3. Where is it stored (e.g., the cloud, third-party apps, etc.) and who has access?
4. Are current safeguards sufficient?
5. What data privacy regulations apply (e.g., HIPAA, CCPA, etc.) and are we compliant?
6. What’s the impact if it’s lost, stolen or exposed?

This question exercise helps identify data ownership, business risks and gaps in current privacy practices, while fostering a top-down culture of accountability. Management and the Board set the tone by committing to privacy, security and ethical data use. The CISO or CPO implements this through policies and controls, while Internal Audit assesses if leadership’s actions align with stated values and regulations. Together, these efforts reveal whether data protection is truly embedded in the organization’s culture and decision-making, and supported by adequate governance, resources and accountability.

Restrict Access: Practicing the Principle of Least Privilege

Limiting data access to employees with task- or oversight-specific needs is an established IT privacy controls practice called the principle of least privilege (PoLP). This line of defense around sensitive information reduces the risks of accidental exposure, leaks or misuse. A helpful question for judging an employee’s access need is, “Do they need this data to perform their job effectively?” If they’d be fine without it, then deny or revoke access. Other crucial data access controls include multi-factor authentication (MFA), role-based access control (RBAC) and password complexity requirements.

Data access reviews should be implemented and enhanced by automated access management tools. These periodic reviews should be done on a formalized schedule, such as quarterly or biannually. The tools can then significantly strengthen data security and facilitate ongoing accountability. They offer services like controls to log and monitor unusual access and audit trails, to be evaluated as part of these reviews. Access changes should then be made as needed.

Discard Unused Data: Implement Retention Policies

Retaining customer data longer than needed is risky, expensive and erodes trust. It increases the chance of data breaches and regulatory penalties. The more data stored, the larger the potential loss in a breach.

Clear, compliant and regularly updated data retention policies are essential for minimizing risk and maintaining customer trust. Define data retention timeframes, ensure regulatory compliance and regularly review them to reflect legal and business changes. Implement secure deletion processes to permanently remove obsolete data.

Include input from a range of relevant stakeholders to help align the policy with organizational needs, uncover risks, ease implementation and foster shared data governance accountability. Departments that may provide value include IT, legal, compliance, operations and business unit leaders.

Trust but Verify: Addressing Vendor Risk in Data Privacy

Data loss is often a third-party vendor’s mistake but still your organization’s responsibility. If you rely on outside vendors – such as payment processors, marketing platforms or cloud service providers – to store, process or manage customer data, it’s essential to ensure they uphold strong data protection standards. While you may outsource the service, you cannot outsource the consequences.

Follow these steps to vet third-party vendors:

• Ask about their data protection policies and procedures.
• Confirm compliance with relevant data privacy laws (e.g., GDPR, CCPA, HIPAA) and industry standards.
• Include contract terms that permit audits, security reviews and/or incident response disclosures. 
• Request and review independent assurance reports (e.g., SOC 2) to assess their control environment.

Periodically revisit these steps, especially as a vendor’s quality, security posture or compliance standards evolve. This level of due diligence can truly help protect your organization from data security risks.

Prepare in Advance: Why an Incident Response Plan is Essential

As seen in the news, even the most secure systems can fail. Data breaches happen. That’s why a well-defined incident response plan is essential. Delays just increase potential damage.

A strong plan should clearly identify who to contact, how to notify affected customers and the steps to contain, resolve and prevent future breaches. Most importantly, it must stay active – not just sit on a shelf. Practice it at least annually through simulations or exercises to ensure everyone knows their roles for quick crisis response. Preparation can significantly reduce damage, preserve trust and maintain compliance with breach notification laws.

The plan should include a comprehensive data backup and recovery strategy for cyberattacks, system failures or accidental loss. To mitigate risk, organizations should:

• Perform regular, automated and thoroughly tested backups.
• Store backups securely and separate from primary systems.
• Establish clear restoration procedures with Recovery Time Objectives (RTOs) aligned to business needs.

These measures are essential for reducing downtime, preserving critical information and maintaining operational continuity during a crisis.

Educate: Train Your Team About Privacy

Everyone who handles sensitive data plays a role in protecting it. Build a privacy-aware culture through regular, practical training tailored to all data handlers – not just high-level security overviews.

Reinforce this with strong leadership: prioritize privacy controls, set clear expectations and model responsible data practices across the organization. Promote habits like not sharing passwords, avoiding suspicious email links and reporting unusual activity through consistent communication, awareness campaigns and as part of onboarding. An informed, vigilant workforce is one of your best defenses against breaches.

The Bottom Line

You don’t always need a fancy IT audit team to protect customer data. These steps can reduce risk, build customers’ trust and avoid costly breaches. Privacy controls aren’t just about checking boxes. They’re about showing stakeholders you respect what they share.

Facing data privacy challenges or need support implementing privacy controls? Sikich can help. Our experts strengthen internal controls, mitigate data risks and enhance compliance with evolving privacy regulations. Contact Sikich today to learn how our tailored solutions can help protect your data and build a stronger, more resilient organization.