Operationalizing Privacy: Why Tools Aren’t Enough
This post is a follow-up to our previous article, “What is Privacy, Really?”. In this installment, we explore why operationalizing privacy goes far beyond adopting a privacy tool. While tools can support the process, they are not a substitute for the foundational work required to embed privacy into an organization’s operations.
Privacy Compliance Isn’t a Tool You Buy – It’s a Culture You Build
In today’s privacy-conscious world, it’s easy to fall into the trap of thinking that purchasing a privacy tool equates to being privacy compliant. Vendors often promise automation, dashboards, and AI-powered magic that can supposedly “solve privacy” for your organization.
But here’s the truth: you can’t outsource the responsibility of privacy to a tool.
The Illusion of Turnkey Compliance
Privacy laws like Europe’s GDPR, California’s CCPA, and Quebec’s Law 25 are complex, evolving, and highly context-dependent. An example of context-dependent is the definition of “Sale” and “Business Purpose” exception under the CCPA.
Under pressure to “do something,” many organizations invest in privacy tools hoping they’ll check the compliance box.
And vendors, for their part, often market themselves as all-in-one solutions. “Install this software, and you’ll be compliant.” Sounds great, right?
But what does “compliant” even mean in this context?
Defining “Compliance” the Right Way
To be truly compliant, your organization must:
Understand what personal data it collects, where it goes, and why.
Have a lawful basis for processing that data.
Implement controls to honor data subject rights (e.g., access, deletion, correction).
Embed privacy-by-design principles into systems and processes.
Train employees and align them with internal policies and external obligations.
Demonstrate all of the above — consistently and across jurisdictions.
None of this can be achieved by a tool alone. Relying on a tool will impact an organization’s genuine understanding of the tasks and challenges at hand.
A Data Subject Access Request (DSAR) tool won’t help if you don’t know where your data resides. A consent management platform is ineffective if your engineering team keeps deploying unregistered cookies. And a data mapping solution only works if your internal processes and culture keep it up to date. As an organization, you should have a program in place to address requirements from a manual and team level, and then delegate identified and required areas to a privacy tool.
Privacy is a Cross-Functional Commitment
Operationalizing privacy means embedding it into the DNA of your organization. It’s not a siloed function — it’s cross-functional:
Legal and compliance teams must translate regulations into actionable policies.
Engineering and IT need to understand data flows, minimize data collection, and integrate privacy controls into system architecture.
Product teams must adopt privacy-by-design, partnering with privacy experts from ideation through deployment.
HR and communications must support awareness, training, and organizational change.
A tool can support these efforts — but it can’t replace them.
Vendors Are a Means, Not an End
Good privacy vendors provide tools — not strategy. A high-quality tool can enable automation, reduce manual workload, and improve visibility. But to make it effective, you still need:
A clear privacy governance framework.
Policy enforcement mechanisms to ensure accountability.
A data inventory strategy — not just a scan.
Training and documentation to demonstrate compliance and build trust.
Using a vendor as part of your toolkit is smart. Relying on a tool to be your privacy program? That’s where things break down. You want to ensure that you are managing the privacy vendor and its tool appropriately, not having them lead you!
Questions to Ask Before Adopting a Privacy Tool
Before implementing a new privacy tool, consider:
What problem are you solving? Is the tool addressing a genuine gap, or is there an existing workaround?
Who is impacted? Which business units will be affected — positively or negatively?
What does onboarding and offboarding look like? If you don’t plan for the tool’s removal, you risk becoming overly dependent. A deeply integrated tool without an exit strategy can be costly and disruptive to replace.
How will training and maintenance be handled? Who owns this responsibility, and how will it scale?
Is there documentation? Do you have materials showing how the tool integrates into your broader privacy program?
Is it scalable and sustainable? Have you evaluated the tool’s long-term viability and technical alignment with your organization’s needs?
Privacy Is a Journey, Not a Checkbox
Achieving real privacy maturity takes time, leadership commitment, and cultural change. It demands tough conversations, shifting priorities, and sometimes rethinking how your organization operates.
Compliance isn’t about appearing to follow the rules — it’s about doing the work.
So the next time someone says, “We’re compliant — we just bought a privacy platform,” ask them:
“Great — but do your teams know what data you're collecting, why, and how you're protecting it? Can you prove it — tomorrow?”
If the answer is no, then you’re not compliant. You’ve just bought a tool.
Final Thought
Privacy isn’t a product — it’s a practice. Let the tools support your efforts, but don’t expect them to lead the way. And most importantly, don’t rely on them too heavily.