Privacy Impact Assessments for Manufacturing

Modern manufacturing operations have converged their IT and operational technology environments in ways that most privacy programs have not accounted for. Enterprise resource planning systems, production floor networks, robotics controllers, and connected equipment share infrastructure that was once physically and logically separate — and the personal information that flows through HR, payroll, and workforce management systems now sits adjacent to industrial control systems in ways that create risk on both sides of that boundary.

Worker data is a genuine privacy obligation, not a secondary consideration. Health and safety incident records, productivity monitoring data, biometric access logs for facility entry and equipment operation, and the surveillance footage that increasingly covers production environments all involve personal information that PIPEDA requires be collected for specific, disclosed purposes. When those collection practices were implemented to serve operational objectives — safety, productivity, access control — they were often not evaluated against what privacy law actually requires. A Privacy Impact Assessment is the systematic process for closing that gap.

Industrial espionage is a risk that sits alongside the privacy dimension but needs to be assessed in the same exercise. Proprietary process specifications, design files, and production data are high-value targets for competitors and state-sponsored threat actors. The same governance gaps that expose worker personal data — weak access controls, inadequate network segmentation, third-party vendor access that was never formally scoped — also create pathways to intellectual property. A well-constructed PIA maps both sets of flows together, because the technical controls that protect one protect the other.

Privacy Horizon conducts PIAs for manufacturers that examine the convergence of IT, OT, and workforce data environments — evaluating where personal information flows through production systems, what monitoring practices around workers actually look like, and how supply chain digitization has extended the data governance boundary to third parties. The output is a practically focused assessment operations, HR, and compliance teams can act on, with documentation that holds up when clients or regulators ask how privacy risk in your environment is managed.

Our approach for Manufacturing

We begin by mapping where personal information enters and flows through your manufacturing environment — from HR and payroll systems through production floor monitoring programs, biometric access records, and the third-party integrations connecting your operations to suppliers, clients, and platform providers. Risk identification evaluates each flow against PIPEDA's collection, purpose, and safeguard requirements, and the mitigation plan is specifically calibrated to your operational realities and the technical constraints of converged IT/OT infrastructure across your facilities. The deliverable is a regulator-ready assessment document and a clearly prioritized remediation roadmap your operations, compliance, and legal teams can work from and execute together.