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In today's world of artificial intelligence-driven innovation, companies are navigating a growing tension: how to honor legitimate customer concerns around data use — like privacy, confidentiality and ethical handling — while pushing forward with the kind of bold data initiatives that drive growth and build smarter products?
The truth is, most companies aren't set up to resolve this contradiction effectively. It's not a question of will. It's a question of structure.
Too often, privacy offices are hidden away in legal or compliance departments, or buried under information technology or security teams. That might have made sense when privacy programs were more about box-ticking. But data governance in the age of AI is something else entirely — something more interdependent, more collaborative and much more strategic.
The missing link between trust and innovation
Customers are right to question how their data is used. They expect transparency, fairness and control. At the same time, organizations are being asked to build smarter systems, leverage personal data to personalize services, and embed AI into everyday workflows. That requires not only more data, but more kinds of data, used in more complex ways.
We can't reconcile these forces with traditional structures that isolate privacy into a legal compliance silo or treat it solely as a risk to be minimized.
What we need is a privacy office that's not only fluent in data protection — but also deeply embedded in the organization's data strategy, customer experience and product development life cycle. That's why location matters.
Why this isn't just about the DPO
To be clear, this isn't a debate about the independence of the data protection officer or the conflicts that arise when placing the DPO within a function that is heavily involved in data processing decision-making or insufficient access to upper management.
Regulations like the EU General Data Protection Regulation and Brazil's General Data Protection Law have laid out well-defined roles and reporting lines for DPOs. Courts and regulators, like Norway's data protection authority, the Datatilsynet, in its March 2025 decision against Telenor, have repeatedly reinforced those boundaries and given clarity around the role.
But the privacy office is not the DPO. It's a broader, operational function — often comprising privacy engineers, analysts and legal advisors — that actively supports decisions around how data is processed, not just whether it complies. And in that role, proximity to the decision-makers — especially in sales, product and marketing — makes a real difference.
The shift toward data governance
As organizations mature, privacy programs are evolving into full-fledged data governance initiatives. And that shift requires more interlocking between product, legal, compliance, security and go-to-market teams.
Done right, data governance becomes a unifying framework, a way to build trust, ensure accountability and empower innovation without sacrificing integrity.
And the privacy office? It's perfectly positioned to lead this evolution. If it's sitting in the right place.
A central hub for data clarity
To get there, more than just new reporting lines are needed. We need new tools. Imagine a central privacy-led data governance platform that: scans product code via application program interfaces with a trusted security vendor — the same ones used today for vulnerability assessments; maps data flows directly to a contract life cycle management system that holds every data-related obligation — whether to a vendor, a customer, or a regulator, and thereby, throughout the organization's estate; and flags gaps in real time, creating a shared dashboard for cross-functional teams to respond together.
This kind of data discovery and obligation-mapping tool would do more than eliminate silos — it would make data governance operational. It would give sales, product, legal and compliance the same consistent and single source of truth, reduce customer friction, and allow everyone to speak the same language.
But to oversee a tool like this, and to drive its adoption across the business, the privacy office can't be buried in a back room. It needs to sit at the intersection of business strategy, data operations and customer trust.
Privacy as a business enabler
When the privacy office is integrated into go-to-market teams, three big shifts happen.
Privacy becomes a sales accelerator. Customers ask tough questions. They want to know how data is handled, whether AI is fair, whether data will be deleted or reused. With a privacy team embedded in sales operations, those answers come fast — and they come with credibility. That builds trust, shortens deal cycles and speeds up deal velocity, and turns transparency into a competitive edge.
AI governance gets smarter, sooner. AI isn't just technical — it's ethical, legal and operational. Sitting closer to the product and sales teams allows the privacy office to translate customer concerns into actionable product feedback, contribute to risk assessments early and train teams in real time as new laws emerge.
Data governance gets real. A privacy office connected to a central discovery and CLM-linked system becomes a cross-functional control tower. It helps ensure that data minimization, accuracy, deletion rights and AI oversight are baked into product design — not retrofitted after launch.
The strategic move forward
Placing the privacy office at the right level in the organization is not about optics. It's about unlocking value.
It's about shifting the perception of privacy from a bottleneck to a bridge — from reactive compliance to proactive trust-building. And it's about recognizing that in the age of AI, the privacy office is uniquely equipped to lead a broader data governance effort that aligns rights, obligations and innovations across the company.
It's time we stopped asking where the privacy office should go based on legacy organization charts — and started asking where it can deliver the most value to the organization.
The answer? Right at the center of your data strategy — home sweet home.
Roy Kamp, AIGP, CIPP/E, CIPP/US, CIPM, FIP, is legal director at UKG.
