Privacy and data protection are no longer an afterthought in a data-driven society, but an essential part of every organization's foundation. Why? Because personal data are the backbone of many business processes and government services. They are indispensable for the achievement of organizational goals, but at the same time also a great responsibility. It directly affects policy goals and public trust.
Without proper protection of this data, trust can be damaged, both internally among employees and externally among citizens, customers and partners. In addition, privacy incidents not only carry legal and financial risks, such as fines and reputational damage, but can also fundamentally erode public trust in the organization.
Data protection should be high on the agenda, fueled by the requirements of the General Data Protection Regulation (AVG) and oversight from agencies such as the Autoriteit Persoonsgegevens (AP). Yet in many organizations, privacy is still often seen as a legal obligation or a technical challenge. And that is precisely where a crucial opportunity and responsibility lies for management.
Privacy maturity does not come from merely establishing protocols or implementing technical solutions. It requires a strong culture, clear ownership, awareness and purposeful leadership. Incidents, such as data breaches, not only pose risks, but often expose broader weaknesses in processes and structures. How an organization responds will determine whether it emerges stronger from the crisis. And that response starts with management.
In this article, I explain why privacy maturity hinges on leadership involvement. Privacy is not a task exclusively for privacy officers or IT specialists; it requires managers who take ownership, provide direction and ensure structural improvements within the organization.
Privacy incidents (such as data breaches) are often seen as problems that need to be "fixed" especially quickly. While an immediate fix is necessary, an incident also presents a valuable opportunity. It not only exposes technical shortcomings, but also points to organizational weaknesses such as faulty processes, unclear responsibilities and lack of awareness.
In my experience, the effective and efficient resolution of a data breach is often slow and uncoordinated, because employees do not know how to act and executives remain aloof or do not dare to take decisions. However, the root of the problem is usually not a lack of necessary technological or legal knowledge, but a lack of ownership.
Three issues that often come to light in incidents:
Lack of responsibility and ownership: Employees and managers do not feel responsible for data protection. It is seen as something "of the privacy department" or "of IT."
Unclear protocols: Processes for reporting and mitigating incidents are unclear, unknown or missing altogether.
Insufficient knowledge: Employees are not trained to recognize risks and respond appropriately.
An incident can therefore serve as a mirror for the organization. It forces reflection: where are the weak spots, and how can management steer for improvement? Taking these questions seriously turns a crisis into an opportunity.
Privacy maturity requires leadership. Management must take responsibility and actively put privacy on the agenda. This means more than setting policy; it involves showing ownership, making knowledge available, and connecting privacy to organizational goals.
Show ownership and responsibility:
Top management must firmly embrace privacy and take responsibility. Privacy is a shared responsibility, but leadership begins with management. Without strong leadership, privacy lingers as a burden rather than a strategic advantage. When management makes it clear that privacy is a strategic priority, it sets the tone for the entire organization. It does not stop at words, however; leadership also means following up by actively taking responsibility for privacy risks within their domain. By leading by example themselves, managers create a culture in which teams take privacy for granted.
Connecting privacy to organizational goals:
For many teams, privacy feels abstract or like an extra burden. It is up to management to clarify how privacy plays a key role in achieving organizational goals, such as reliability, efficiency and protecting reputation. After all, a data breach is more than a legal issue; it directly affects policy goals and public trust.
Invest in training and awareness:
Management plays a crucial role in ensuring that employees act appropriately in the event of an incident. This requires providing targeted training, clear communication and removing uncertainty about the correct steps to take in the event of a data breach. In addition, it is essential to create a safe environment in which employees dare to report incidents without fear of reprisal. By removing this fear and normalizing reports, management creates an environment in which employees can act in a prepared, confident and proactive manner.
Measuring is knowing:
Privacy maturity is measurable using maturity models and KPIs that provide insight into the current state and steps needed for growth. Maturity models help plot the organization on a scale with ad hoc responses at one extreme and strategically integrated privacy management at the other. Establishing KPIs gives an organization measurable goals, such as the number of DPIAs conducted or timely responses to data breaches. These tools not only allow management to drive concrete improvements, but also promote accountability and transparency within teams. It provides a clear basis for monitoring successes, addressing risks and structurally embedding privacy in the organization.
A mature privacy culture begins with insight, and that insight is provided by an up-to-date and insightful processing register. This register, mandatory under the AVG, provides an overview of personal data processing operations within the organization. For management, it is not only a legal requirement, but primarily a strategic tool.
The processing register makes clear which personal data are being processed, for what purpose and what risks are involved. This enables management to identify risks in a timely manner and take appropriate measures. In addition, an up-to-date register contributes to transparency and compliance. Non-compliance can lead to fines and reputation damage, while a well-maintained register shows that the organization takes its obligations seriously.
When incidents occur, such as a data breach, the processing log is essential to quickly identify what data is involved and what steps are needed. This immediate insight enables a targeted and rapid response, preventing further damage and mitigating risks. By acting quickly, sensitive data is better protected, escalation is prevented and the trust of data subjects is maintained. Moreover, the register supports compliance with reporting obligations, which prevents legal and financial sanctions. This makes the register indispensable in minimizing the impact of incidents.
Without a current and complete processing registry, the basis for effective privacy management is missing. It is therefore essential for management to take the registry seriously and ensure that it is systematically updated. The registry is not just an obligation, but a valuable tool for strategic leadership and risk management.
Privacy incidents are inevitable, but how an organization responds to them determines whether it remains a threat or becomes an opportunity. Management plays a key role here by taking ownership, creating awareness and steering for concrete improvements. An up-to-date processing registry, thoughtful incident management and engaged leadership combine to form the foundation for privacy maturity.
Privacy is not an afterthought or obligation; it is a strategic advantage that strengthens trust, improves processes and mitigates risk. This requires leaders who not only comply with privacy, but also promote it as a core value within the organization.
So step forward as leaders. Make sure your teams understand why privacy is important and their role in it. Work together on an up-to-date processing registry, use incidents as learning moments, and connect privacy to organizational goals. By doing this, you not only make the organization stronger, but also lay the foundation for continued trust and success.
