Why CISOs Should Embrace Privacy Frameworks to Reduce Risk & Build Value

Organizations with a strong cybersecurity foundation but no formal approach to data privacy have a significant opportunity to enhance their risk posture. By adopting a privacy framework, organizations can achieve a similar reduction in risk as seen with early investments in cybersecurity, gaining an immediate boost in risk management and resilience. 

While cybersecurity focuses on protecting assets, effective data privacy management reduces the sensitivity and footprint of data, making cybersecurity efforts more efficient. Organizations that prioritize privacy differentiate themselves by demonstrating a commitment to safeguarding data, which promotes customer trust and creates opportunities for partnerships where privacy assurances are required. 

Adopting a framework like the NIST Privacy Framework or ISO/IEC 27701 enables businesses to leverage best practices, establish a foundation for compliance, and mitigate risks to both the business and individuals whose data is processed. 

Business Benefits of Privacy Framework Adoption 

While data privacy is often perceived as a cost center, adopting a formal privacy framework creates business value, particularly for companies managing significant volumes of consumer data. Achieving that business value requires re-imagining what data privacy means for the business. In recent years, Apple, Firefox, and Vrbo have each demonstrated the brand benefits of differentiating themselves on privacy. 

However, to achieve those benefits, stakeholders across the business must embrace, and not resist, changes to operations required for data privacy best practices. To achieve that, stakeholders need to understand the potential upside and work with the privacy team to identify the metrics that will help them evaluate success over time. 

Depending on business priorities and current state of compliance maturity, adopting a privacy framework can have a variety of benefits. These are some examples: 

• Expanding Market Access: Establish core policies for compliance across jurisdictions, making adaptation to new or changing regulations easier. 
• Risk and Cost Reduction: Improve data inventory and controls to reduce breaches, protect reputation, and reduce costs. 
• Identifying Blind Spots: Address areas of vulnerability often overlooked in privacy programs that evolve on an ad hoc basis or involve acquisitions. 
• Cyber insurance: Demonstrate risk mitigation to insurers by proactively adopting privacy frameworks, improving terms. 
• Customer Trust and Loyalty: Strong privacy practices build trust, fostering loyalty and driving retention. 
• Data Subject Rights Enablement: Integrate data subject rights into design processes to reduce unscheduled and urgent demands on engineering resources. 
• HR Oversight: Improve oversight of third-party processors handling sensitive employee data.   

Align Privacy Frameworks with Cybersecurity Initiatives 

Organizations should build on their existing cybersecurity investments and select a privacy framework that aligns with that program. In the US, the NIST Privacy Framework is often paired with the NIST Cybersecurity Framework for a holistic approach to managing security and privacy risks. Globally, the ISO/IEC 27701 Privacy Framework offers ISO-aligned guidance on implementing privacy best practices. 

Privacy frameworks are not just about compliance; they enhance resilience by helping organizations understand the data they collect, why they collect it, how it is used, and where vulnerabilities exist. This awareness minimizes operational and reputational risks from privacy incidents. When fully integrated, privacy frameworks complement existing cybersecurity efforts, allowing organizations to be proactive rather than reactive to threats. In an era where privacy incidents can cause significant damage, a robust privacy framework is key to maintaining a strong brand image. 

To demonstrate these benefits, it helps to understand the components of a privacy framework. The NIST Privacy Framework exemplifies the scope of privacy frameworks, organized into the following functions: 

• Identify: Understand the organization's data landscape, including what data is collected, how it is used, and where it is stored. Identifying data flows and processing activities creates a clear map of privacy obligations and risks, helping allocate resources effectively. 
• Govern: Outlines essential policies and procedures for managing privacy risks and operations, aligning with business strategy, and training the workforce. Privacy operations must adapt to evolving business products, priorities, and the legal landscape, requiring continuous monitoring and iteration of policies. 
• Control: Establish controls to limit unnecessary data collection and retention, reduce the attack surface, and respond effectively to data subject requests. 
• Communicate: Emphasize transparency in privacy policies and just-in-time notices to build customer trust and differentiate from competitors. 
• Protect: Ensure appropriate security measures are in place to safeguard data, adopting elements from the NIST Cybersecurity Framework to maintain comprehensive protection. 

Other frameworks vary in structure but share foundational principles and similar results when effectively implemented. For example, ISO/IEC 27701 adds privacy-specific controls to the ISO/IEC 27001 approach, integrating a Privacy Information Management System (PIMS) to address data protection requirements. While the NIST Privacy Framework emphasizes flexibility and risk management, ISO/IEC 27701 takes a controls-based approach that emphasizes prescriptive guidance closely aligned with the EU’s GDPR and other global privacy laws. 

To ensure the best solution for your business, select a privacy framework that aligns with existing cybersecurity practices to ensure seamless integration. 

Next Steps to Mature Privacy Programs 

The benefits of a privacy framework are clear: reduced risk, stronger customer trust, and greater efficiency. The question is how soon an organization can leverage this strategic advantage. 

To mature your risk management practices by adopting a privacy framework, consider: 

• Identify the Right Framework: Align with existing cybersecurity practices for seamless integration. 
• Assess Current State: Conduct a gap assessment to establish a baseline. 
• Create a Maturity Roadmap: Identify areas where improvements will have the greatest impact. 
• Plan Re-Assessment: Set a timeline to ensure continuous improvement. 

At Coalfire, we regularly work with partners on a variety of privacy assessments and frameworks. Our goal is to help you understand the purpose of the framework, prioritize the controls that are the most important for your specific environment, and align on a remediation roadmap that reduces risk to both your business and your end users. 

Our team can guide your organization through each step, from gap assessments to maturity roadmaps, transforming privacy from a compliance obligation into a strategic advantage.