Processes and Governance

Privacy program

Identify, classify, secure, manage, and delete enterprise-wide personal information across all media.

Assess risk tolerance and target maturity.

Identify, track, and manage personal information.

Respond promptly and confidently to incidents and subject access and deletion requests.

White Paper

Developing a Data Retention Policy to Meet Privacy Data Minimization Requirements

Recorded Webinar

Using M365 to Create a Personal Data Inventory

Article

Should You Combine Your Privacy and Records Management Programs?

How we help

With new and changing legal and regulatory privacy requirements and increasing privacy-related risks, companies need to be able to manage privacy information in an compliant, efficient, and scalable manner.

Our privacy program services combine policies, processes, technology, training, monitoring, and auditing to help organizations identify, classify, secure, manage, and delete sensitive information across electronic and paper media.

Explore our privacy program services

Privacy Assessment and Roadmap

Risk tolerance review and targeted program maturity assessment and planning.

Personal Data Inventory

Identify and document all personal information that an organization collects, uses, stores, shares, and transfers across systems and processes.

M365 Personal Data Inventory Portal

Leverage the capabilities of M365 to track and manage personal information.

Privacy-enabled data retention policy creation and update, privacy subject access and deletion request, and privacy-enabled incident response.

Disposition and Monitoring

Process development for defensible disposition and remediation as well as privacy audit, monitoring, remediation, and recordkeeping.

Fractional and Transitional Privacy Staffing

Privacy roles and responsibilities, staff training, and Fractional and Transitional Privacy Manager services.

If you’ve been asking yourself…

“What types of personal information do we access, transmit, share, and store across our organization?”

“How do we effectively comply with a multitude of different privacy laws?”

“Does the personal information already reside in a well-governed repository? Can this information be easily accessed, produced, and deleted or de-identified?”

“Has the personal information been sold or shared with a third party?”

“Where is this personal information stored and managed across our structured, unstructured, and semi-structured data repositories as well as onsite and offsite paper stores?”

“How does personal information flow across our various repositories? How does personal information flow into and out of our systems from and to third parties?”

“How do we ensure that our privacy program does not conflict with recordkeeping, eDiscovery, and other compliance requirements? How do we resolve these conflicts?”

“How do we communicate our privacy requirements and strategy effectively and credibility to senior management?”

“How do we respond to personal information subject access requests from individuals? How do we execute “right to be forgotten” and personal information erasure requests from customers, employees, and other individuals?”

“What policies and notices do we need for managing our personal information? Where and how should these be published?”

“What is the appropriate retention of personal information, and how do document the legitimate business need for retaining this personal information to ensure our practices are defensible?”

“What policies and notices do we need for managing our personal information? Where and how should these be published?”

“What gaps do we have in our privacy program, and what is our strategic roadmap over what period of time for addressing these gaps?”

“What processes should we follow that allow us to both comply with notification procedures and reduce risk in the event of a breach? Have we proactively developed these processes?”

“Who should be involved in developing and executing the privacy program and how do we make this an enterprise-wide effort supported by multiple stakeholders?”

“How do we train employees on privacy processes?”

“What audit processes are needed to ensure we are compliant?”

“What internal, external and technology resources will be required to execute our program over what period of time? Can we leverage technology we already own?”

“How do we consistently and defensively delete personal information?”

…you’ve come to the right place.

Learn more about our services and explore related resources below.

Related resources

Recorded Webinar

Creating a Modern, Compliant, and Easier-to-Execute Records Retention Schedule for Privacy and AI

A well-designed schedule not only ensures regulatory compliance but also fosters collaboration with business units, reduces conflicts, and supports automation of classification and disposition processes.

Recorded Webinar

Information Governance 101

Gain an overview of the essential building blocks of an effective program including records and data retention, privacy and data minimization, and the role of technology, processes, and training in making governance sustainable.

Recorded Webinar

Using M365 to Create a Personal Data Inventory

Rather than investing in expensive and complex tools, organizations can take a more practical, scalable, and compliant approach by leveraging Microsoft 365 to manage personal data inventories more effectively.

What We Do

Our privacy program services

We support all stages of privacy program development, from foundational assessment and planning to operational processes and training, defensible disposition and monitoring, and organizational development and staffing.

Our tailored approach focuses on ensuring compliance, reducing risk, enabling operability and scalability, and designing with the flexibility to meet new or changing privacy requirements, all in a cost-effective manner.

Privacy Assessment and Roadmap

We determine a right-sized privacy program for your organization and build a practical plan to achieve it.

Privacy projects are complex, involving a multitude of policies, processes, technology, and training, affecting diverse groups, and addressing different media types. Especially when facing a tight timeframe, it is important to have an end-to-end plan that defines up-front what you want to do, when, and how much.

With an assessment and roadmap, you gain clarity on where you stand and confidence in the level of privacy maturity you actually need.

Assess & Evaluate

We assess your current privacy practices, governance structures, data handling processes, and controls and evaluate program maturity, identifying strengths, gaps, and risk exposures through document review and targeted stakeholder interviews.

Gap Analysis & Remediation Plan

We translate findings into a clear gap analysis and prioritized remediation plan aligned to your risk tolerance, regulatory obligations, and business objectives.

Strategic Roadmap

We deliver a practical, board-ready roadmap for you to get there without overengineering your program or underestimating your risk. The final strategic roadmap provides a structured, phased plan that includes:

Recommended projects and initiatives
Major tasks and milestones
Required staffing and technology
Budgetary cost estimates
Realistic implementation timelines

Not every organization needs a ‘sports car’ privacy program. For most organizations, a well-designed, efficient ‘sedan’ or ‘golf cart’ program delivers stronger results than an overly ambitious and unsustainable approach. We help determine the appropriate maturity level based on:

Volume and sensitivity of personal data held
Number and geography of consumers or employees impacted
Storage environments and data lifecycle practices
How broadly data is shared internally and externally
Regulatory exposure and enforcement risk

Personal Data Inventory

We create a detailed inventory of personal information workflows and repository analysis across the enterprise.

Compliance with privacy rules necessitates tracking how personal information is collected, how it flows through the organization, and where it is stored. Called a Personal Data Inventory (PDI), this is an inventory of customer and employee personal information throughout its lifecycle for compliance with privacy rules.

The process of creating a PDI reveals patterns that may be unique to each business, helping to identify privacy data. Some privacy data can be identified through technology that searches for known patterns like social security numbers, addresses, drivers’ licenses, and ‘regular expressions.’ Other types of privacy data, such as inference data, may require more advanced search techniques.

The PDI includes a workflow analysis, mapping all processes that involve collection and use of personal information, who has access to this data, to whom the data is transferred outside the company (if anyone), and how long the personal data is stored in each location. It also includes a repository analysis, identifying all locations where personal data may be stored such as databases, email, and file shares, both on-premise and cloud-based, and including all designated locations of this data: the original source as well as any inadvertent copies (for example, employees may store an extract of a database as a file on their desktop).

M365 Personal Data Inventory Portal

We help you leverage the capabilities of M365 to track and manage personal information.

Organizations increasingly recognize the need to understand the personal data they collect, use, and store, but turning that goal into a practical, sustainable process remains a challenge. Personal data is often scattered across systems and departments, and many data inventories quickly devolve into static, hard-to-maintain spreadsheets. Rather than investing in expensive and complex tools, our M365 Personal Data Inventory portal leverages Microsoft 365 to manage personal data inventories more effectively.

Risk-Driven Privacy Policies and Notices

We identify gaps in your existing policies, notices, and opt-out documentation, recommend practical improvements, and deliver updated, regulator-ready documentation aligned with your risk profile and regulatory exposure.

Privacy laws and regulations continue to expand, requiring organizations to update existing policies, create new notices, formalize procedures, and strengthen operational controls. Designing a program to comply with a single state or country often means redesigning it again as new laws emerge. Managing these requirements one law at a time is inefficient and unsustainable.

Instead, we help organizations build a flexible baseline privacy capability (what we call privacy information agility) so policies and procedures can be adapted efficiently as requirements evolve. We review, enhance, and draft documentation including:

Updated Privacy Policies
Privacy Notices
Consent Notices and Opt-Out Mechanisms
Deletion and Data Subject Rights Procedures
Data Security Classification Standards
Privacy Impact Assessment (PIA) Frameworks
Data Breach and Incident Response Plans

Disposition and Monitoring

We develop processes for defensible disposition and remediation as well as privacy audit, monitoring, remediation, and recordkeeping.

Holding on to privacy information that is obsolete, expired, or not needed for legal, regulatory or business use increases the risk of privacy non-compliance and \exposure should a data breach occur. Likewise, implementing personal data deletion requests in environments with large amounts of legacy data is both difficult and expensive.

We work with organizations to implement ongoing disposition of old, unneeded documents and data. This includes developing strategies for deletion of legacy, older structured data in databases; unstructured data including files on file shares, desktops and within SharePoint and other content management systems; legacy semi-structured data such as email; and inactive data held in backup tapes and onsite and offsite paper records.

Fractional and Transitional Privacy Staffing

We help support and coordinate your organization’s privacy operations.

By embedding a fractional privacy professional who has direct access to Contoural’s full delivery organization, your organization has a single, consistent point of contact backed by deep, on-demand expertise across privacy, legal research, retention scheduling, information governance, defensible disposition, privacy, and technology implementation.

Fractional information governance services provide hands-on support for day-to-day privacy operational tasks, documentation, and follow-through, including tracking action items, maintaining records inventories or logs, coordinating with IT or vendors, ensuring commitments are completed, and updating standard operating procedures (SOPs) and other lightweight documentation. The emphasis is on reliability and execution, closing the gap between policy and practice.

Fractional information governance and privacy services are delivered under a flexible engagement model tailored to the organization’s needs. This can include full-time support over a period of months or fractional support of 50% or 25% for a longer period.

This approach allows organizations to access experienced information governance expertise without the cost or rigidity of a full-time role, while still maintaining continuity, accountability, and institutional knowledge. Sustain effective information governance and records management programs, reduce risk, and support legal and regulatory obligations in a cost-effective and scalable manner.

Connect with a member of the Contoural team to learn more about our information governance consulting services.

As an independent provider, Contoural does not sell or resell any products, take product referral fees, or provide discovery services such as matter-specific document identification, document collection, or document review. Our advice is based solely on the needs of our clients and is not driven by the sale of products.