Privacy Compliance: It’s Not Just About Cookie Banners
Before you roll your eyes at the meme, let me explain something critical about privacy compliance projects...
Everything matters.
Yes, even cookie management on your website is important. If it weren’t, regulatory bodies like Brazil’s ANPD wouldn’t have released guidance like the "Cookies and Personal Data Protection" manual - The same happens with CNIL in France, among others.
The problem is when projects stop there, focusing only on the visible "frontend" of compliance while neglecting the backend—the real foundation of data protection.
What’s Important on the Frontend?
Cookie Banners Done Right: Use professional tools to manage and log consent properly.
Privacy Notices: Offer clear and transparent information to users.
Privacy Portals: Make it easy for individuals to exercise their rights.
Consent Management: Collect and store consent in a compliant way.
App Adjustments: Ensure your iOS/Android apps and their tracking libraries are privacy-compliant.
These are great starting points, but they’re just the tip of the iceberg.
What About the Backend?
Employee Training: Awareness and training across the organization are non-negotiable.
Comprehensive Diagnostics: Map out risks and data activities for all departments, branches, and subsidiaries.
ROPA (Record of Processing Activities): Map and document data processing activities and sub-activities.
Third-Party Risk Management: Audit and review contracts with vendors.
Data Discovery: Identify and organize data when handling large volumes or complex datasets.
Data Redaction: Apply anonymization techniques for sensitive data.
DPIA/RIPD: Prepare structured impact assessments, ready for when they’re needed.
Don’t Forget System Migrations and Integrations
Here’s the truth: not all your systems are privacy-ready, and some foreign vendors may not prioritize LGPD or similar laws in smaller markets.
You’ll likely face challenges like:
Switching vendors and handling messy data migrations.
Tackling the manual flow of data, aka the spreadsheet chaos.
Eliminating manual processes through automation, which often requires software development, third-party integrations, or even cultural shifts within the company.
Final Thought
The frontend of compliance—the part users see—is essential. But without a strong backend, it’s just a nice outfit with no substance. Privacy compliance is about building a foundation that works at every level, from banners to backend systems.
Make 2025 the year your compliance moves beyond appearances. 🚀