The reality of privacy work

A few weeks ago, I shared a post on LinkedIn that apparently struck a nerve. It started with a simple observation: "They gave you the privacy officer title. They didn't give you a budget. Or a team. Or any actual authority."

Within hours, the post was liked by hundreds, reposted dozens of times and my inbox was flooded with messages from privacy professionals around the world saying the same thing: "I thought I was the only one."

The responses confirmed what I suspected: most privacy professionals are managing significant compliance responsibilities while drowning in reactive work and competing demands from across their organizations. The volume and consistency of the responses revealed this isn't a problem affecting a few unlucky privacy officers.

After 25-plus years in privacy, I've come to believe this isn't a temporary problem that organizations will eventually fix — it's the permanent operating environment for our profession.

And, counterintuitively, it might be the key to building programs that work.

What we don't say at privacy conferences

Privacy conferences can be filled with case studies of mature programs with dedicated teams, executive champions and healthy budgets. Recommended frameworks for structuring privacy programs often assume organizational structures that barely exist outside Fortune 50 companies.

Privacy certification courses teach legal compliance obligations and best practices but rarely consider the actual resources required to turn those requirements into practical, business operations that can be maintained over time.

It's tempting to imagine that real privacy leadership begins once there's executive alignment, a clearly defined roadmap, a generous tooling budget and enterprise-wide engagement.

In reality, few privacy programs begin under those conditions. Instead, the appointment of a privacy lead is usually reactive — triggered by a new regulation, a vendor requirement, or a client question that leadership can no longer ignore. What follows is a formal title, an inbox full of expectations and very little infrastructure to support it.

Day-to-day, the reality for most privacy officers looks nothing like those idealized conference scenarios. Many are handed a vague mandate to "make us compliant," expected to eliminate enterprise risk while marketing storms their inbox at 4:57 p.m. on Friday needing immediate approval for Monday's launch.

Sales builds lead lists however they want, insisting that "just gathering business cards at trade shows" doesn't require privacy consideration. IT treats data mapping requests like suggestions they'll get to "eventually." And leadership keeps asking if the organization is compliant yet, while rejecting every budget request.

This disconnect breeds exhaustion and even paralysis. When professionals are stretched impossibly thin, are constantly reactive, and can't see how to get ahead of the chaos, it's natural to think real privacy programs are only possible with resources they'll never have.

Just as privacy officers are barely keeping their head above water with traditional privacy challenges, organizations are now expecting many to tackle artificial intelligence governance, too, because who else would handle algorithmic accountability, model bias assessments and AI risk frameworks? The scope keeps expanding while the resources remain the same.

What I learned in the trenches

My own journey began at DoubleClick, now owned by Google, in the early days of privacy compliance. At the time, the IAPP was still a new organization and there were no tools, no frameworks or any playbooks to follow.

There were only two of us navigating this uncharted territory, but I was fortunate to work alongside someone whose passion for privacy was matched only by her commitment to doing the right thing and building up everyone around her. My colleague always took accountability, created space for us to learn and believed deeply that privacy work mattered, not just for compliance, but for people.

Even with that kind of exceptional leadership, most of our work was reactive: fielding urgent questions with no precedent to guide us, scrambling to research answers, and hoping we hadn't missed something critical.

When we didn't know how to handle something, we'd call colleagues at other organizations to see what they were doing or reach out to outside counsel when we had the budget for that. We were figuring it out together, trading insights and making educated guesses about what compliance actually meant in practice.

Looking back, that reactive scramble taught me something invaluable: personally managing every compliance request teaches which privacy practices fit into existing workflows versus which require constant workarounds. When vendor reviews can't be delegated, the critical due diligence steps emerge to the forefront, separating meaningful procurement from mere checkbox compliance. The privacy requirements that can survive real business pressure and those that immediately crumble can be clearly seen when assessments can't be automated.

Upon reflection, this hands-on experience taught me something counterintuitive about what makes privacy programs successful.

Why resources don't equal results

There's a common assumption that privacy programs fail because they lack resources, but that misses the real problem. Having a budget doesn't automatically create effective programs — it takes judgment to know what matters.

The hardest part of the journey for privacy professionals is developing the ability to distinguish between what feels urgent and what is truly important. When every request seems like a crisis and every question demands an immediate answer, you become constantly reactive, never able to build anything sustainable. This is where even well-funded organizations stumble.

I've seen this pattern repeat across companies with generous privacy budgets. They build comprehensive programs that look impressive, but don't reduce risk or improve operations. They mistake thoroughness for effectiveness, creating processes so complex that people work around them rather than with them. The pursuit of comprehensive compliance becomes the enemy of meaningful progress. Organizations grow so fixated on addressing every possible risk scenario that they never address the risks that matter.

The work behind the title

The success stories in privacy are rarely about teams who waited for ideal conditions. They're about professionals who started where they were — with limited access, unclear ownership and very little internal precedent — and built something useful anyway.

They didn't focus on what they lacked; they focused on what they could influence and:

• Building relationships across departments.
• Translating legal requirements into operational steps.
• Establishing repeatable, lightweight workflows.
• Showing that privacy can reduce friction, not just risk.

Most importantly, they resisted the urge to make privacy impressive before it was functional. They started small, solved real problems and used those early wins to make the case for more.

This approach may not be glamorous, but it works. Building a defensible privacy compliance infrastructure is not achieved by visibility alone. It's accomplished through consistent, well-executed, human-driven practices, whether or not the organization is ready to call them strategic.

Creating momentum in less-than-perfect conditions

The privacy professionals I've witnessed who achieve the most meaningful results are those who have developed the judgment to focus on what drives risk reduction. Effective privacy professionals can distinguish between genuine priorities and manufactured urgency. They build programs that work in practice and can be explained, maintained and defended with clear evidence.

From years of working across industries and stages of maturity, I've seen three strategies work particularly well for privacy professionals operating under imperfect conditions.

Stop trying to be everywhere at once. The question that dominated the responses to my LinkedIn post was, "How do you build a privacy program when you have responsibility but no authority?" The answer isn't about gaining formal power, it's about prioritizing strategic visibility over tactical exhaustion.

Trying to "touch everything" is unsustainable and can build resentment. Be the person who can handle vendor negotiations without endless delays, resolve data subject requests without creating panic, and provide practical guidance that people can implement and defend when questioned.

Stop building, start embedding. You don't always need to create new processes to build effective privacy compliance. Often, privacy succeeds when it is embedded in existing business operations: marketing calendars, IT procurement workflows and vendor onboarding procedures. Meet teams where they already are and make it easier for them.

This approach recognizes that sustainable privacy work happens when it feels like an operational improvement rather than additional burden. The most adoptable processes are those that strengthen existing workflows rather than competing with them for attention and resources.

Anchor privacy work in what it actually is. Too often, privacy professionals feel pressure to frame their programs as business differentiators. For most organizations, however, the work is compliance hygiene. It is foundational, unglamorous and non-optional. Rather than overselling privacy as a competitive advantage, it's more effective to establish its value as core accountability: clear evidence, sustained ownership and a defensible privacy compliance narrative.

This grounding allows privacy programs to mature without needing to be marketed as something they aren't. It creates realistic expectations and sustainable progress rather than the boom-and-bust cycle that comes from overpromising strategic value.

Moving the field forward

One of the most striking aspects about the response to the original LinkedIn post was how many experienced professionals from across regions and industries said some version of, "I thought it was just me."

It's not.

We are collectively navigating the growing pains of a field that is still maturing. And in the process, many privacy professionals are doing strategic work and building operational programs with minimal structure and earning influence one conversation at a time.

That work matters — even if it isn't always recognized and even if the title doesn't come with a team or the roadmap is being sketched in real time. I have seen this profession be so much stronger for the persistence of the professionals in it.

As more of us speak openly about the reality of privacy work, what it takes, where it breaks and how it builds, we continue to move the field forward — not through ideal structures, but through shared commitment, practical action and the belief that privacy isn't something you wait to lead.

It's something you do, even when the conditions aren't perfect.

Teresa Troester-Falk, CIPP/US, is the CEO and founder of BlueSky Privacy.