Editor's note: The IAPP is policy neutral. We publish contributed opinion and analysis pieces to enable our members to hear a broad spectrum of views in our domains.
Privacy compliance programs today are under more pressure than ever. Growing regulatory expectations, relentless client scrutiny and increasing operational complexity have left many organizations struggling to keep pace. The instinct has been to turn to technology for solutions, but technology isn't the problem.
Privacy compliance efforts aren't broken because technology failed us. They're broken because we tried to automate what wasn't truly owned in the first place.
I first fell into the world of privacy compliance more than 20 years ago, when the IAPP was newly formed — I remember the conference where President and CEO J. Trevor Hughes, CIPP, proudly announced 500 members.
There were no playbooks to follow. Almost no one was talking about structured privacy frameworks or how to build programs that could stand up to scrutiny. We were too busy reacting and making judgment calls without clear precedent.
Within organizations, privacy was often seen as a box to check. It was considered a legal formality, not a strategic function. When legal, product, sales or marketing reached out to the privacy team, it was usually with questions we were expected to answer on the spot. What counts as personal data? Do we need consent here? Can this data flow across borders?
We were brought in at the 11th hour, asked to "take a quick look" right before launch, after months of work had already gone into the product. There was little structure to fall back on — only instinct, ad-hoc documentation and a growing list of urgent, high-risk decisions landing in our laps.
We leaned on our judgment, called outside counsel when we could, traded "what are you doing?" emails with peers, and built answers from scratch. We made our best guesses, wrote things down, tracked decisions in spreadsheets, and hoped we hadn't missed something critical.
As privacy laws kept coming, this approach cracked. Many privacy professionals weren't operating from strong structures or formal programs. We continued to react and patch things together as best we could.
Around the time of the EU General Data Protection Regulation, the promise of privacy tech arrived — offering scale, automation and relief. We were excited. Personally, after more than a decade working in the trenches, I had the opportunity to contribute to innovative thinking in operational privacy compliance and spent over five years leading global privacy strategy at one of the earliest privacy technology firms.
It was a time of genuine enthusiasm. We believed technology could improve the day-to-day work of privacy officers, but we also knew that simply automating manual processes without rethinking them would only scale their flaws.
Good privacy tech would have to be reimagined to strengthen the core — not replace it. Every feature we developed was designed to solve real, persistent problems of demonstrating compliance and anticipating future needs. We built thoughtfully, carefully and always with the principle that automation must follow ownership — not substitute for it.
I am still proud of that work and of everyone who was part of it. Although the market moved faster than we could, and many of those early products have since been absorbed or disappeared, the principles behind them are more important than ever.
Looking across the field of privacy tech today, I experience a very different reality. The market has been flooded with privacy tools promising quick fixes, automated integrations, artificial intelligence-powered solutions and one-click compliance. Many organizations have purchased these promises after flashy sales demonstrations. Yet, years after these purchases, many find themselves no better off.
Too many tools sit underused or abandoned. The costs are increasing at every renewal. Often the purchasers did not fully understand that these tools require human oversight, ongoing maintenance and organizational maturity. Too many purchases have become shelf ware.
Ironically, manual workarounds are creeping back in, and the demand for customization is loud as companies realize out-of-the-box solutions can't fit their unique structures. Compliance feels as reactive as ever.
And now, AI is accelerating the same mistake: promising to automate what was never operationally clear to begin with. If the foundations aren't built, automation doesn't fix the gaps — it multiplies them.
After all these cycles, I believe more than ever that the problem is not poor technology. It is the belief that a tool can solve what hasn't been owned internally.
Privacy compliance is not a technology problem. It is first and foremost an ownership problem. If the foundational structure isn't there — if there is no clarity around data practices, no ownership of workflows, no real accountability — technology simply accelerates confusion.
That's the shift I believe we are seeing now. What's old is new again. The organizations that feel most confident in demonstrating privacy compliance aren't the ones with the most advanced tech stacks — they're the ones that own their privacy programs from the ground up.
They've built foundations rooted in responsibility, sustained ownership and reliable, well-maintained evidence. And often, they've done it using simple tools: spreadsheets that track activities with discipline, shared drives that house real documentation, workflows built into platforms they already use.
This isn't about going backward. I remain a strong believer in the promise of privacy technology and its ability to scale, reinforce and streamline well-established practices. But true confidence in an organization's ability to demonstrate compliance, especially under pressure, begins with fundamentals — taking full ownership of the work, assigning sustained responsibility and maintaining clear, reliable evidence of compliance.
Technology should enhance this foundation, not substitute for it. AI will not save organizations that have skipped the work of operational clarity — it will only reveal how much they neglected to build.
In the end, it isn't better tools or faster automation that will define the future of privacy compliance. It's disciplined ownership, clear evidence and operational systems that can hold up — with or without technology.
Teresa Troester-Falk, CIPP/US, is CEO and founder at BlueSky Privacy.
