Cyber Risk Advisory
Getting the Board on Board: Motivating Executive Buy-In for Privacy
Securing executive buy-in is crucial to unlocking the full potential of a privacy program. Even achieving baseline compliance requires support from leadership.
As data usage expands across an organization, privacy leaders face the challenge of influencing multiple departments, often without direct authority. To succeed, they must rely on strategic influence and relationship-building. Without strong leadership support, privacy initiatives risk being deprioritized amid competing business demands.
So, how can privacy leaders effectively gain Board support when tasked with building or enhancing a privacy program?
This blog will explore key strategies to engage senior stakeholders, including leveraging regulatory risks ('the stick') and emphasizing how Board prioritization drives privacy program success and creates business value ('the carrot'). Finally, it will summarize the foundations for effective partnership with the Board.
The Stick: Regulatory Risks and Consequences
Conversations around "the stick" - the potential consequences of non-compliance - are common but often overemphasized. Discussions frequently focus on GDPR fines and regulatory actions, but many organizations assess the risk of enforcement as relatively low unless they operate in industries aligned with recent enforcement trends, such as dealing in location data.
While enforcement case studies offer valuable insights, they are often viewed as operational concerns rather than strategic imperatives. Many privacy leaders report that they are expected to maintain compliance and adapt to new requirements, without clear mandates from leadership or the Board.
Regulators, however, are shifting their focus. The FTC, for example, has increasingly emphasized the concept of personal liability for senior executives and Board members who are aware of privacy violations. Similarly, California's proposed regulations (accepting public comment through February 19, 2025) require senior executives to personally certify compliance with cybersecurity and privacy assessments.
Regulatory pressures are increasing. Yet many organizations still view data breaches as their primary privacy risk. This often leads to an over-reliance on cybersecurity measures. However, while there is no privacy without cybersecurity, once a cybersecurity program begins to mature, formally adopting a complementary data privacy program addresses different risks and may significantly reduce the risks associated with a data breach.
The First Carrot: Board Prioritization Drives Success
On January 21, 2025, ISACA released its latest State of Privacy report. The report summarizes responses to a September 2024 survey of ISACA constituents with an ISACA privacy-related certification or a privacy designation in their job title.
The report repeatedly integrates questions around board prioritization of privacy. Key findings include that, of 57% of respondents who believe the Board of Directors "adequately prioritized privacy":
- 80% identified documented privacy policies procedures and standards as mandatory (vs. 68% of other respondents)
- 54% feel completely or very confident in the organization's ability to ensure the privacy of its sensitive data (vs. 40% of other respondents)
Additionally, 58% of respondents believe the Board views the privacy program as ethically required because of the enterprise's mission, or as a competitive advantage, or as some combination of compliance, ethics, and competitive advantage.
In other words, when the Board actively prioritizes privacy, organizations are more likely to establish comprehensive policies, allocate appropriate resources, and embed privacy into their core business strategies. This commitment fosters a culture of accountability, where privacy is viewed as a strategic asset rather than a compliance burden, ultimately enhancing trust and long-term business success.
The Second Carrot: Privacy as an Enabler of Innovation
The ISACA report highlights the strong correlation between the adoption of privacy by design and the Board's prioritization of privacy programs. It also reveals that organizations where privacy by design is in place tend to adopt AI solutions for privacy-related work at a higher rate.
This finding is a compelling case study for an analogy shared by IAPP President and CEO Trevor Hughes at the IAPP's Privacy. Security. Risk. conference in 2023. When describing privacy programs and their impact on emerging technologies, Hughes posed the question: What are brakes good for? While the obvious answer might be to slow down, Hughes argued that brakes actually enable speed by providing the confidence to move forward safely.
Rather than being viewed as a constraint, a well-implemented privacy program—like brakes—empowers businesses to embrace innovation, such as AI technologies, with greater confidence and control.
The ISACA report does not explore the question of how AI risks are managed more broadly across the enterprise. However, it does identify a correlation between one AI use case and the adoption of privacy by design more broadly, which is in turn associated with strong Board prioritization of privacy programs. This correlation is a promising indicator that privacy-related risks of emerging technologies are more proactively addressed in these organizations.
In other words, these findings suggest that organizations with strong Board interest in privacy are better positioned to leverage AI effectively and responsibly, enhancing both compliance and innovation.
Next Steps
To move forward effectively, privacy leaders must focus on a multi-faceted approach that combines both regulatory compliance and strategic business value. Engaging the Board requires a tailored narrative that goes beyond regulatory obligations and highlights the competitive, ethical, and operational advantages of a well-structured privacy program.
- Align Privacy Goals with Business Objectives
Privacy professionals should demonstrate how privacy initiatives align with broader business goals such as customer trust, market differentiation, and operational efficiency. By framing privacy as a value driver rather than just a compliance necessity, the Board is more likely to recognize its strategic importance. - Leverage Real-World Case Studies
Showcasing successful privacy programs within similar industries can provide tangible proof points. Highlighting organizations that have turned privacy compliance into a market advantage can help build a compelling case for investment. - Develop Board-Level Reporting Metrics
Boards respond well to clear, quantifiable metrics. For this audience, privacy leaders should focus on developing KPIs that reflect business impact, such as deals closed where privacy was a key negotiation point. - Address Emerging Risks and Opportunities
Given the rapid adoption of emerging technologies such as AI, privacy programs should proactively assess associated risks and present actionable strategies to the Board. Demonstrating readiness to manage these risks can position privacy as a forward-thinking function.
By adopting these next steps, privacy leaders can create a compelling case that resonates with the Board, ensuring that privacy remains a strategic priority and continues to evolve alongside the organization’s growth and technological advancements. And once that is in place?
Consider adopting a privacy framework to ensure a comprehensive approach that aligns with business objectives. At Coalfire, we regularly work with partners to mature their privacy programs, develop strategic roadmaps, and align initiatives with business goals.