Operationalizing Privacy: The Role of ERM
In our last post, we discussed where to begin when thinking about operationalizing privacy. The first and most critical step is defining your privacy program. This begins with analyzing which privacy laws and regulations, industry best practices, and internal frameworks apply to your business operations. Once these are identified, you can build your framework around them and then focus on individual program elements, such as Privacy Impact Assessments, Data Subject Access Requests, and Privacy by Design, to establish a functional and scalable privacy program.
As you build your framework and program, an important consideration is determining which elements and functions to prioritize. This decision should be driven by the level of risk associated with each missing or underdeveloped privacy function within your organization.
A natural next step in this process is incorporating your organization’s Enterprise Risk Management (ERM) framework into the development of your privacy program.
Why the ERM Framework?
An ERM framework is an organization’s method for identifying, assessing, managing, and monitoring risks that could impact the business. One of the primary benefits of ERM is its holistic view of risk and its ability to define the organization’s overall risk appetite. The ERM is tailored to the context of your organization (e.g., size, industry, goals). From a privacy perspective, ERM provides a shared structure and common language for discussing and evaluating risk.
Applying ERM principles to your privacy framework allows you to assess privacy risks more effectively and communicate those risks to leadership in a way that resonates at the enterprise level. By aligning privacy risks with broader business risks, leadership can view privacy as part of the overall risk landscape rather than as a standalone compliance exercise.
As business objectives evolve, aligning your privacy program with ERM also makes it easier to adapt. Because ERM frameworks shift alongside business strategy, privacy practices can be adjusted within an already-established structure rather than rebuilt from scratch.
This alignment also strengthens your ability to advocate for privacy-related initiatives and requirements. Privacy teams are often perceived as speaking a different language or as being the “office of no.” By tying privacy requirements back to the ERM framework, you anchor them to a company-wide mandate rather than positioning them as isolated or obstructive requests. This can help in advocating for resources.
At its core, this approach reinforces a critical principle: privacy should not operate in a silo.
When privacy professionals speak the same risk language as the rest of the organization, collaboration across business units becomes significantly easier. Shared terminology and frameworks foster alignment, understanding, and cooperation.
The ERM Framework
While ERM implementation varies by organization, the following elements are commonly present, though they may be labeled differently or grouped:
Risk identification – Identifying risks that could impact projects and business objectives
Risk assessment – Evaluating the likelihood and potential impact of identified risks
Risk response – Determining how to address risks by avoiding, mitigating, transferring, or accepting them
Risk monitoring – Tracking risks over time and reassessing them as conditions change
Reporting and governance – Reporting risks to leadership and escalating issues as necessary
As you align your privacy program to the ERM framework, it is important to pause and consider how privacy risk should be defined in a way that both aligns with ERM and preserves the essence of privacy requirements. This includes determining how privacy risks will be identified (consider identifying harm here), who the appropriate risk owners and decision-makers are within the organization, and how those risks will be communicated to the business and governance bodies in a meaningful and actionable way.
Final Thoughts
Integrating privacy into your organization’s ERM framework is not about diluting privacy requirements; it is about strengthening them. By aligning privacy with enterprise risk, you position privacy as a strategic business function rather than a reactive compliance obligation. This alignment enables clearer prioritization, more effective communication with leadership, and greater adaptability as business objectives evolve.
Ultimately, a privacy program that speaks the language of enterprise risk is better equipped to scale, influence decision-making, and embed privacy into the fabric of the organization. When privacy is treated as part of the enterprise risk conversation, it moves from being a barrier to becoming a business enabler.