Virtual CPO
Services
Full-service privacy leadership that starts with a comprehensive assessment of your data practices and transitions into ongoing program management. From tracking cookies to regulatory filings, we handle it all.
The Growing Privacy Imperative
Most organizations collect far more personal data than they realize. Hidden trackers, unmanaged cookies, shadow data stores, and undocumented vendor integrations create regulatory exposure that grows every day.
How It Works
Our vCPO engagement is structured in two phases: a thorough initial assessment to understand where you stand, followed by ongoing monthly management to keep your program running and compliant.
Initial Assessment
A comprehensive audit of your current data practices, tracking technologies, vendor relationships, and compliance posture. We find every place personal data lives and every way it moves through your organization.
Typically 4-8 weeks depending on organizational complexity
Monthly Program Management
Ongoing execution and oversight of your privacy program. We handle day-to-day compliance operations, respond to regulatory changes, manage data subject requests, and continuously improve your privacy posture.
Continuous engagement with monthly deliverables and reporting
Initial Privacy Assessment
Before we can protect your data, we need to know exactly what you have, where it lives, how it flows, and who can access it. The initial assessment is the foundation everything else is built on.
Complete Data Inventory
Catalog every system, database, spreadsheet, and SaaS tool that stores or processes personal data. Map data types (PII, PHI, financial, biometric) to their storage locations and identify who has access.
Data Flow Mapping
Trace how personal data enters your organization, moves between systems, gets shared with vendors, and (ideally) gets deleted. Identify every integration point, API connection, and data transfer.
Tracking & Cookie Audit
Scan all web properties for tracking cookies, pixels, beacons, fingerprinting scripts, and third-party tags. Identify every tracker loading on your sites, what data it collects, and where that data goes. Flag non-compliant tracking that fires before consent.
Consent Mechanism Review
Evaluate your current cookie banners, consent management platform, opt-out mechanisms, and preference centers. Assess whether consent collection meets GDPR, CCPA, and applicable state law requirements.
Privacy Policy & Notice Audit
Review all privacy policies, notices at collection, and disclosures for accuracy and legal compliance. Verify they reflect actual data practices, cover all required categories, and meet readability standards.
Vendor & Third-Party Assessment
Inventory every vendor and third party that receives personal data. Review data processing agreements, evaluate vendor privacy practices, and identify gaps in contractual protections.
Regulatory Gap Analysis
Map your current practices against applicable regulations (GDPR, CCPA/CPRA, state laws, HIPAA, COPPA, etc.). Produce a prioritized findings report with risk ratings and remediation recommendations.
Technical Privacy Scan
Inspect your applications and infrastructure for privacy-impacting issues: excessive data collection, missing encryption, improper data retention, exposed personal data in logs, analytics tools collecting more than disclosed.
Risk Assessment & Roadmap
Synthesize all findings into a prioritized risk matrix and remediation roadmap. Deliver an executive summary for leadership and a detailed action plan with timelines, owners, and estimated effort.
Assessment Deliverables
Ongoing Privacy Program Management
Privacy is not a one-time project. After the initial assessment, we transition into ongoing management of your privacy program, handling the day-to-day operations that keep you compliant as regulations, your business, and the threat landscape evolve.
Compliance Operations
Regulatory Monitoring & Response
Track new and evolving privacy laws, enforcement actions, and regulatory guidance. Assess impact on your organization and implement required changes before deadlines hit.
Data Subject Request Management
Handle access, deletion, correction, opt-out, and portability requests end-to-end. Manage intake, verification, cross-system fulfillment, and response within regulatory timelines.
Consent & Cookie Governance
Continuously monitor your websites for new tracking technologies, unauthorized cookies, and consent banner functionality. Ensure new marketing tags and pixels are reviewed before deployment.
Vendor Privacy Lifecycle Management
Onboard new vendors through privacy review, negotiate and maintain DPAs, conduct periodic reassessments, and manage vendor offboarding with data return/deletion verification.
Breach Response Coordination
Lead privacy incident response when breaches occur. Assess notification obligations across jurisdictions, draft consumer and regulator notifications, and coordinate remediation.
Strategy & Governance
Privacy Impact Assessments
Conduct PIAs and DPIAs for new products, features, acquisitions, and data processing changes. Integrate privacy review into your product development and procurement workflows.
Policy & Documentation Maintenance
Keep privacy policies, internal procedures, records of processing, and compliance documentation current. Update as your data practices, vendor relationships, or regulatory landscape change.
Employee Training & Awareness
Deliver role-based privacy training to engineering, marketing, HR, and customer-facing teams. Run awareness campaigns and provide just-in-time guidance when teams have privacy questions.
Privacy-by-Design Reviews
Review new features, marketing campaigns, and data initiatives before launch. Identify privacy risks early and recommend design changes that satisfy requirements without blocking product goals.
Executive Reporting & Metrics
Provide monthly privacy program status reports with KPIs: DSR volumes, consent rates, open risks, vendor compliance status, regulatory changes, and program maturity progress.
Monthly Deliverables
What We Typically Find
Most organizations are surprised by the scope of their privacy exposure. These are common findings from our initial assessments.
Undisclosed Tracking Cookies
Third-party cookies and tracking pixels firing before consent is collected, or not disclosed in your privacy policy at all. Marketing tags, retargeting pixels, and analytics scripts that share personal data with ad networks without user knowledge.
Shadow Data Stores
Personal data in places no one expected: old spreadsheets on shared drives, exported CSVs in email, test databases with production data, chat logs containing customer PII, and abandoned SaaS tools still holding records.
Missing or Stale DPAs
Vendors processing personal data without signed data processing agreements, or DPAs that haven't been updated since CCPA amendments, new state laws, or changes in how data is actually shared.
Broken Consent Flows
Cookie banners that don't actually block cookies when users decline. Opt-out links that don't propagate to all systems. Consent preferences lost during session changes or across subdomains.
Over-Collection & Retention
Collecting personal data fields your business doesn't need, retaining data far beyond any legitimate purpose, and lacking automated deletion processes for expired data.
Privacy Policy Gaps
Policies that don't mention entire categories of data collection, fail to list all third-party recipients, omit required disclosures for certain state laws, or describe practices the organization no longer follows.
Regulatory Coverage
Deep expertise across the global privacy regulatory landscape, from established frameworks to the latest state laws.
GDPR (EU/UK)
CCPA / CPRA
US State Privacy Laws
HIPAA Privacy Rule
COPPA
GLBA / FCRA
PIPEDA (Canada)
Industry Frameworks
Engagement Structure
Every engagement begins with the initial assessment. Monthly program management scales based on your organization's size, regulatory complexity, and data processing volume.
Initial Assessment
Comprehensive audit of your data practices, tracking technologies, vendor relationships, policies, and compliance posture. Produces a complete data inventory and prioritized remediation roadmap.
Monthly Program Management
Ongoing execution and oversight of your privacy program. We serve as your dedicated privacy leader, handling compliance operations so your team can focus on building product.
Add AI Governance
Using AI to process personal data? Extend your vCPO engagement with AI governance to cover automated decision-making compliance, training data privacy, AI-specific impact assessments, and transparency requirements, all under unified privacy leadership.
Protect What Matters
Lead with Privacy
Turn privacy from a compliance burden into a competitive advantage. Schedule a consultation to discuss your organization's data protection needs.