MVP program · Professional services
Minimum Viable Privacy Program for Marketing Agencies
A ten-person agency pitching its first bank, insurer or national retailer needs a working privacy baseline before procurement comes calling: consent hygiene on every list, locked-down access to client platforms, a short set of real policies, and a team that has been trained once properly. Our Minimum Viable Privacy program builds exactly that foundation over a year, for $5,499 CAD, without hiring anyone or pausing client work.
Reviewed by the Privacy Horizon team · Last reviewed
What you're protecting
The baseline that keeps a small shop credible
Minimum viable does not mean cosmetic. Five foundations separate agencies that win enterprise work from agencies that stall in review.
A consent story for every send
Knowing, for each list you mail on a client's behalf, where the addresses came from and what they agreed to, recorded somewhere you can produce on request.
Controlled access to client platforms
Two-factor authentication on every Business Portfolio, manager account, ESP and CMS seat, credentials vaulted rather than shared in chat, and a habit of removing access when people leave.
A small set of honest policies
Data handling, acceptable use and incident basics that describe your actual five-desk reality, not a downloaded enterprise framework nobody follows.
A named privacy contact
One person, even part-time, who owns questions about lists, uploads and client data requests, so accountability exists before regulators or clients ask for it.
First-incident readiness
Enough preparation that a hijacked Page or a leaked export triggers a known sequence instead of a panicked group chat at midnight.
Regulatory map
The legal floor that applies at five people, not fifty
None of the regimes touching agencies waits for headcount, which is what makes a baseline urgent rather than aspirational.
PIPEDA has no small-business exemption
Handling customer personal information in commercial activity brings the full set of fair-information principles, including accountability and safeguards, from your first client engagement onward.
CASL applies to your very first campaign
Consent, identification and unsubscribe requirements attach to each commercial electronic message, and the sender carries the burden of proof from day one, at any company size.
The regulations govern your message footer
The Electronic Commerce Protection Regulations prescribe the identification and contact details every message needs, mechanical requirements that small shops most often get wrong.
One Quebec client triggers Law 25 duties
Serving a Quebec brand or building a site collecting Quebec users' data brings officer designation, plain-language policy and default-off obligations regardless of your size or where your office sits.
What goes wrong
How unprepared small agencies get caught
The forcing events arrive on their own schedule, and each is dramatically cheaper to prepare for than to survive.
The questionnaire you cannot answer
A dream client's procurement portal wants policies, training records and access controls you have never written down, with a submission deadline measured in days.
The hijack with no playbook
An infostealer takes a founder's browser session and the agency discovers, mid-crisis, that nobody knows Meta's recovery process or holds a second admin path.
The complaint on a borrowed list
An early-days list of uncertain origin draws a CASL complaint, and the consent proof the law expects from the sender simply does not exist.
The AI habit that predates the rules
Client data flows casually into free-tier tools for months before anyone asks what those services retain, and the cleanup is harder than the policy would have been.
Growth outpacing the paperwork
Hiring past 24 employees in Ontario adds the electronic-monitoring policy obligation, one of several thresholds that sneak up on scaling shops.
Our mvp program for marketing agencies
What the MVP year includes for an agency
A structured foundation delivered through coaching and workshops, sized for a shop without a compliance function.
Baseline privacy gap review
A focused look at your lists, platform access, contracts and tools against what the law and your target clients expect, producing a short, honest gap list.
Prioritized control recommendations
The highest-impact moves first, typically consent record-keeping, authentication hygiene and offboarding, so early effort buys visible risk reduction.
Policy development
The starter set drafted for your operation, covering data handling, acceptable use and the client-facing documents enterprise onboarding will request.
Twelve hours of expert coaching
On-call guidance through the year for the questions that actually arise: a list of doubtful origin, a new tool, a client's data clause, a close call.
Training and human-risk assessments
Ten seats of role-relevant training so the whole team learns the consent and phishing fundamentals, with assessments showing where risk remains.
Readiness assessment workshops
Working sessions that turn the gap list into finished foundations and leave you with a structure that scales as the client roster grows.
How the engagement runs
A year of MVP, mapped for a small agency
The program front-loads discovery, then converts findings into foundations at a pace a billable team can sustain.
Step 1
Review where you stand
The gap review examines lists, access, contracts and tooling in your first weeks, establishing the honest starting line.
Step 2
Fix the sharpest risks first
Prioritized recommendations get implemented through workshops, starting with whatever would fail a client review or regulator question tomorrow.
Step 3
Build the durable pieces
Policies land, training runs, and the named privacy contact gets equipped, with coaching hours absorbing the questions along the way.
Step 4
Finish with a scalable structure
By year end you hold a documented baseline that answers questionnaires, and a clear view of when to step up to ongoing support.
What it costs
What MVP costs and where it fits
Minimum Viable Privacy is $5,499 CAD per year, billed annually on a 12-month term, including the gap review, policy development, readiness workshops, twelve coaching hours and training with human-risk assessments for ten seats. For a small agency it replaces the awkward alternative: assembling the same foundation from an hourly consultant at several times the cost.
When client demands intensify, monthly obligations pile up, or Quebec work needs a supported officer, the natural next step is our Virtual Privacy Office retainer. MVP is deliberately designed so nothing you build in year one gets thrown away on the way up.
Marketing Agencies: MVP program questions, answered
Four things, done properly: consent records for every list you touch, two-factor and vaulted credentials across client platforms with real offboarding, a compact policy set matching how you work, and one training pass with a named privacy contact. That baseline satisfies most first questionnaires, holds up in a CASL dispute, and takes a year of light effort rather than a compliance department. MVP exists to deliver precisely this scope.
Procurement gatekeepers look for written policies they can file, proof of access control over the systems that will hold their data, evidence your team is trained, and a plausible answer on incident handling. Some will also want your privacy contact's name and your sub-processor list. None of it requires certification at this stage; it requires the foundations to exist and be documented, which is what the MVP year is engineered to produce before the questionnaire arrives.
Yes, because for agencies the two are inseparable. The gap review examines list provenance and unsubscribe handling, the policy work includes sending procedures with the required identification elements, and the training gives account staff the express-versus-implied grounding they need. What MVP does not do is retroactively repair years of undocumented consent, though it will show you which lists carry that problem and what to do about it.
It establishes the foundation and identifies your Law 25 obligations, including officer designation and what your client-site builds must do about default-off profiling. Sustained Quebec work usually justifies stepping up to ongoing support, since impact assessments for out-of-province transfers and register maintenance are recurring duties rather than one-time setup. We will tell you plainly during the gap review which side of that line your client mix puts you on.
You keep everything: the policies, the records structure, the trained team and the documented baseline. Some agencies renew MVP to maintain momentum, others graduate to the Virtual Privacy Office as client obligations deepen, and some simply operate the foundation independently for a while. The program's design goal is that the year leaves you meaningfully harder to compromise and materially easier to onboard, whichever path follows.
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