How to Build a Privacy Program from Scratch: A Step-by-Step Guide for Small Businesses
If you’re a small business, “privacy program” can sound like something only enterprise teams can afford.
In reality, a privacy program is just a set of practical habits, controls, and documentation that prove you handle personal information responsibly—and respond well when something goes wrong.
Here’s a straightforward way to build one from scratch without getting buried.
Step 1: Assign ownership (or it won’t happen)
Pick a clear owner for privacy decisions. It doesn’t have to be full time, but it does have to be explicit. If you don’t have internal capacity, a Virtual Privacy Officer (vPO) can keep the program moving.
Step 2: Map what you collect (and why)
Start a simple data inventory:
- What personal info you collect (customers, employees, leads)
- Where it’s stored (apps, spreadsheets, inboxes, cloud storage)
- Who has access
- Why you collect it (purpose)
- How long you keep it (retention)
Step 3: Identify the highest-risk data and workflows
Prioritize where a mistake would hurt most:
- Payment and financial identifiers
- Health-related data (even “light” health signals)
- Government IDs
- Support channels (tickets, screenshots, call recordings)
- Admin access to production systems
If you want a structured starting point, explore our Assessments.
Step 4: Tighten access (the highest-ROI control)
Most incidents come down to access.
- Turn on MFA everywhere
- Use least privilege
- Remove stale accounts quickly
- Separate admin accounts from daily-use accounts
Step 5: Set vendor rules
Create a simple vendor checklist for tools that store or process personal data:
- What data does the vendor receive?
- Where is it stored/processed?
- Who can access it?
- What controls are available (MFA, encryption, logging)?
- How do we exit if needed?
Step 6: Write the “minimum viable” policies
You don’t need an encyclopedia. You need policies your team will actually follow. At minimum:
- Internal privacy handling rules
- Information security policy (access, devices, acceptable use)
- Retention + deletion rules
- Incident response plan (who does what, when)
If you want help building these quickly: Policy Development
Step 7: Add lightweight assessments for change
Most privacy failures happen during change: new features, new vendors, new integrations.
- Use PIAs for privacy risk: Privacy Impact Assessment (PIA)
- Use TRAs for security risk: Threat and Risk Assessment (TRA)
Step 8: Train the team (short and role-based)
Most issues are human: oversharing, mishandling exports, weak passwords, risky screenshots.
For practical training: Custom Training
Step 9: Create a simple cadence
- Monthly: review access changes + new vendors
- Quarterly: review incidents/near-misses + update policies
- Annually: refresh training + re-run key assessments
Want the fast path?
If you’re starting from zero, the quickest path is to implement a baseline program first, then deepen over time.
That’s what Minimum Viable Privacy (MVP) is designed for.
Interested to learn more? Book a call. Still deciding? Start with FAQs.