Privacy Program Maturity Model

Building a Privacy Program

Building a privacy program can be hard. Maintaining and maturing one to meet evolving regulations, support operational challenges, and withstand external events can make it feel impossible. To make this task more approachable, it's essential to understand where you stand today and what you need to accomplish tomorrow to take your program to the next level.

We developed the DataShyre Privacy Program Maturity Model to serve as a framework and guide for privacy professionals seeking to better understand and benchmark their privacy program and its growth trajectory. In the ensuing sections, you'll learn:

How to use this model to guide your privacy program's operations
What the different levels of privacy program maturity are
Which elements are essential for a holistic privacy program
How you can make the most use of your time and resources as a privacy professional

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Scoring Methodology

By working through the 16 privacy program elements listed in this model and considering which of the five levels best represents the given element's maturity level, you can calculate an overall privacy program maturity score. The score totals correspond to different levels of overall maturity:

Level One: Reactive Maturity (16–31 points)
Level Two: Provisional Maturity (32–47 points)
Level Three: Formalized Maturity (48–63 points)
Level Four: Monitored Maturity (64–79 points)
Level Five: Proactive Maturity (80 points)

It's best to think of this scoring methodology as a general framework to guide your privacy program's development. The specific gaps and weaknesses you identify during the evaluation process should be considered weightier than the ultimate score.

Keep track of your program's score using our scorecard template.

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Privacy Program Maturity Levels

Level 1: Reactive

Privacy-related activities are conducted in a reactive, one-off manner, perhaps in response to a breach or as a "band-aid" effort to comply with a new regulation. There is no consistency or standardization in how privacy issues are addressed.

Level 2: Provisional

Some basic mechanisms for managing data privacy and compliance needs are in place, though not formalized. Procedures for managing data privacy exist but are not fully documented, comprehensive, or integrated into the organization's operations.

Level 3: Formalized

A privacy program exists with defined policies, procedures, and standards that are integrated into the organization's operations.

Level 4: Monitored

The organization is actively managing and assessing its privacy program. Processes and procedures are reviewed on a regular cadence to assess efficacy and identify gaps.

Level 5: Proactive

The privacy program is a central part of the organization's operations and strategic roadmap. The program is continuously monitored to anticipate gaps and needs before they arise.

The DataShyre Privacy Program Maturity Model