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03/09/2026
6-step framework for managing privacy risk
For advertisers and marketing teams, privacy risk can feel like a big, abstract issue. Like any other challenge, it benefits from clarity and simplification. It becomes much easier to manage when you break it into a series of practical steps.
AG Take: We recommend a six-part framework for clients that want to take a more active approach to data and privacy management.
- Privacy Leadership: There needs to be a person or team with clear responsibility for how data is collected, shared and used.
- Data inventory: Know what data you are sharing, why you are sharing it and where it is stored.
- Gap analysis: Assess the data you collect, store and share, and identify areas of risk.
- Data Protection Impact Assessment: Document the potential impact if something goes wrong.
- Mitigation: Collect only what you need, use it for the intended purpose and be transparent about how it is used.
- Auditable record: Maintain the processes, policies, contracts and records needed to demonstrate good data governance.

