Privacy under the CISO: Strategic integration of privacy and security functions

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Executive Summary

As organizations navigate the complex digital landscape, integrating privacy management under CISO leadership has emerged as a strategic approach to unify data protection efforts. Nearly half of CISOs now oversee privacy functions—up from approximately one-third five years ago—driven by converging cybersecurity and privacy risks alongside demanding regulatory environments.

Key findings include:

• Operational Challenges: Organizations face significant hurdles when merging privacy under CISO leadership, including organizational alignment issues, cultural resistance, potential conflicts of interest, technical complexity, skills gaps, and resource constraints.

• Strategic Benefits: Integration offers substantial advantages: a holistic risk posture, operational efficiencies, centralized governance, improved compliance, reduced breach impact, enhanced trust, and greater agility in responding to emerging risks.

• Implementation Approaches: Successful implementation requires adopting integrated frameworks like NIST and ISO standards, embedding privacy-by-design principles, defining clear roles in hybrid governance models, leveraging specialized program management methodologies, and fostering collaborative cultures.

• Regulatory Considerations: Different regions impose varied requirements—the EU's GDPR explicitly requires independence for Data Protection Officers, while U.S. laws offer more flexibility in organizational structure.

• Industry Variations: Implementation models vary significantly by industry, with financial services and healthcare typically maintaining more separation due to regulatory requirements, while technology and manufacturing industries often adopt more integrated approaches.

Operational Challenges in Merging Privacy Under the CISO

Organizational Alignment and Silos

Privacy has traditionally been the domain of legal or compliance teams, while CISOs focus on cyber threats. Merging these domains requires cross-functional collaboration that can be difficult to establish and maintain. Privacy teams frequently operate with a compliance-first mindset centered on policy development and interpretation, while security teams often prioritize technical controls and threat mitigation.

Many companies report that privacy responsibilities "have been changing hands and still remain rather fuzzy," moving from legal to IT and even to marketing as data use evolves. Overcoming these siloed approaches requires deliberate governance planning and ongoing coordination mechanisms.

Cultural Resistance and Mindset Gaps

Security and privacy professionals historically approach problems differently. Security teams may be "tone deaf to privacy," assuming strong data protection automatically equals privacy compliance. The cultural divide manifests in different professional languages, risk assessment approaches, and prioritization frameworks:

• Privacy professionals typically emphasize individual rights, transparency, and purpose limitation

• Security professionals focus on confidentiality, integrity, and availability

Bridging this cultural divide requires more than structural changes—it demands awareness building, cross-training, and leadership commitment.

Conflict of Interest Risks

If the CISO directly assumes the Data Protection Officer role (as required under laws like GDPR in some cases), potential conflicts of interest must be managed. GDPR mandates that a DPO be independent in monitoring compliance. A CISO who defines and implements data processing security might be "auditing himself" if also acting as DPO.

This inherent conflict can lead to regulatory penalties. For instance, an e-commerce company in Germany was fined €525,000 because its DPO also served in an operational data management role, compromising independence.

To avoid such conflicts, organizations must either keep certain privacy oversight functions independent or create checks and balances (such as having a separate privacy officer or an impartial DPO reporting outside the direct security hierarchy).

Technical and Process Complexity

Integrating privacy controls into existing security operations presents significant technical challenges. Privacy compliance involves managing data inventories, consents, data subject access requests (DSARs), data retention and deletion policies, and other requirements that span many IT systems and business processes.

The IAPP found that privacy teams struggle with process integration—particularly regarding the implementation of technical controls that simultaneously address security and privacy requirements. Ensuring that security tools (like data loss prevention, identity management, logging systems) also meet privacy requirements (e.g., minimization, purpose limitation) requires careful design.

There is also the challenge of integrating privacy technology (consent management platforms, DSAR tools, privacy incident response workflows) with security infrastructure. Organizations report difficulties in creating unified data inventories that serve both privacy compliance and security classification needs.

Skills Gaps and Training Needs

Effective privacy management requires expertise in legal compliance, data governance, and ethical considerations—domains that traditional cybersecurity teams may not be fully equipped to handle. As CISOs increasingly assume responsibility for privacy, reskilling becomes essential. Security leaders must develop fluency in privacy laws, data protection principles, and regulatory obligations.

At the same time, privacy professionals often need to deepen their understanding of cybersecurity architectures, threat models, and technical safeguards to collaborate effectively with security teams.

A 2024 industry survey highlighted this skills gap: only 38% of privacy professionals reported confidence in their knowledge of cybersecurity practices, while just 41% of security professionals felt adequately informed about privacy regulations.

This capability divide reinforces the need for cross-training, joint education programs, and integrated team structures to ensure both functions can operate cohesively in managing modern data risk.

Workload and Resource Constraints

Privacy compliance at scale is a complex and resource-intensive effort—involving global regulatory tracking, privacy impact assessments (PIAs), data subject request (DSR) workflows, and vendor risk reviews. When these responsibilities are folded into the security organization, they can overwhelm already stretched CISO teams, particularly if integration is not supported with adequate headcount or funding.

According to a 2024 CISO survey, 67% of security leaders reported insufficient resources to manage both cybersecurity and privacy effectively. Without dedicated staffing or budget for privacy, integration efforts risk becoming ineffective or unsustainable, ultimately creating operational blind spots and compliance exposure.

To succeed, organizations must treat privacy as a strategic function—not an add-on—and ensure resource models reflect the full scope of joint responsibilities.

Data Management Complexity

Organizations managing significant data volumes face particular challenges in integrating privacy and security. The sheer complexity of maintaining comprehensive data inventories, mapping data flows, and implementing appropriate controls across both domains requires sophisticated approaches and technologies.

Both privacy and security teams need visibility into data creation, movement, storage, and deletion—but often approach this tracking with different objectives and using different tools. Creating a unified approach to data lifecycle management represents a significant operational hurdle.

Measuring Privacy Return on Investment (ROI)

Unlike cybersecurity investments—which can be evaluated through metrics such as incident reduction, risk scores, or cost avoidance—privacy investments often deliver value that is harder to quantify. Benefits like improved brand trust, regulatory posture, and ethical data practices typically lack direct ROI measures.

According to Cisco’s 2024 Privacy Benchmark Study, only 23% of organizations reported having clear metrics to evaluate the return on privacy investments.

This lack of measurement maturity poses a challenge for CISOs and executive teams, particularly when privacy and security functions compete for shared budgets. Without robust ROI models, privacy initiatives may be underfunded or deprioritized, despite their strategic importance in compliance, customer retention, and reputation risk management.Benefits of Unified Privacy and Security Leadership

Holistic Risk Posture and Unified Strategy

Combining privacy and cybersecurity oversight allows for a more comprehensive view of information risk. Data breaches and privacy violations are interrelated threats, so having one leader over both enables holistic risk assessments and mitigation.

With integrated leadership, common objectives (like protecting sensitive data) can be pursued without departmental barriers. The CISO can ensure security controls (encryption, access control, monitoring, etc.) are aligned with privacy requirements, and vice versa, resulting in a stronger overall risk posture.

One outcome is fewer blind spots—privacy risks in how data is collected or used are more likely to be identified during security risk reviews when the teams work as one.

Operational Efficiency and Streamlined Processes

A major expected benefit is improved efficiency in governance and operations. When privacy and security share processes and infrastructure, there is less duplication of effort. For instance, an integrated team can build a single data inventory that serves both security classification and privacy compliance purposes.

Technical controls can be leveraged for dual purposes—rather than privacy officers designing controls and security implementing separate ones, a unified team implements once.

Incident response is another area of efficiency: a combined privacy-security incident response process can handle both cybersecurity incidents and data breaches in one workflow, meeting both breach notification regulations and cybersecurity containment needs.

Centralized Governance and Accountability

Placing privacy under the CISO creates a single point of accountability for information protection. This centralized governance can strengthen policy enforcement and oversight. A centralized team can enforce standard policies for data handling, retention, and consent, backed by security monitoring to ensure compliance.

It also simplifies reporting to senior management and the board: the CISO can report on cybersecurity and privacy risk in one combined dashboard or briefing, providing leadership with a complete picture of data risk management.

Improved Compliance and Reduced Breach Impact

With privacy and security working hand-in-hand, organizations are often better positioned to comply with complex regulations and prevent costly incidents. Regulatory mandates (GDPR, CCPA, etc.) require both policy and technical measures—an integrated team can address both simultaneously.

In the event of a data breach, having privacy under the CISO means the incident response will automatically account for notification duties and mitigation of harm to individuals, not just IT containment. This can reduce regulatory penalties and litigation costs since the response is more compliant and swift.

Trust, Reputation, and Business Value

According to Cisco's 2023 Privacy Benchmark study, privacy investment delivers tangible business value, with an average 1.8x return on investment—including gains in consumer trust and loyalty.

Customers are increasingly privacy-conscious and will reward companies that safeguard their data. A unified security/privacy function can roll out privacy-by-design features in products faster and ensure marketing and data science initiatives respect customer preferences, thereby differentiating the company.

Agility in Emerging Areas

New technology risks (such as AI and machine learning privacy concerns) require both security and privacy oversight. Organizations with integrated teams can more nimbly govern these emerging challenges.

For example, AI systems may ingest personal data, raising questions about bias, transparency, and consent. A CISO who also oversees privacy can establish AI governance policies that address data protection and security simultaneously.

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