Building a Privacy Working Group: A Cross-Functional Framework
Jan 31, 2026Building a Privacy Working Group: A Cross-Functional Framework
How to make privacy everyone's responsibility and not just Legal's problem
Privacy can't be solved by your legal team alone. It requires coordination across product, media, creative, and operations — and these can be teams that don't typically work closely together and often speak different languages.
A privacy working group is how you bridge that gap. It's a cross-functional team that meets regularly to ensure everyone understands the privacy implications of their work and has a voice in how you balance effectiveness with trust.
This isn't about creating more meetings or bureaucracy. It's about preventing the kinds of problems that emerge when teams work in silos: advertising campaigns that reveal too much, product features that collect data no one authorized, vendor contracts that expose audience information, or privacy policies that don't match actual practices.
Here's how to build one that actually works.
What a Privacy Working Group Does
A privacy working group is a standing cross-functional team responsible for:
Core Responsibilities
- Reviewing campaigns and initiatives before launch
Advertising campaigns, new product features, data partnerships, vendor contracts — anything that affects how you collect or use audience data. - Establishing organizational privacy guidelines
What types of data collection are acceptable? What targeting practices are off-limits? How do you handle sensitive information? - Creating shared understanding
Building common language and awareness across teams about privacy principles so everyone knows what matters and why. - Identifying and resolving conflicts
Between performance goals and privacy standards, between what platforms allow and what your organization should do, between different interpretations of regulations. - Monitoring external changes
New regulations, platform policy updates, industry best practices, enforcement actions, and determining how they affect your operations. - Ensuring policy matches practice
Your privacy policy should accurately reflect what you actually do, not what legal thinks you do or what you aspire to do.
The goal is accountability without bureaucracy, making sure privacy is considered in every relevant decision without slowing everything down.
Who Should Be Involved
The composition of your privacy working group matters. Too small and you'll miss critical perspectives. Too large and you won't get anything done.
Core Members (Required)
Legal/Compliance Representative
Why they're essential: They provide regulatory context, interpret privacy laws, assess legal risk, and draft policy language.
Common pitfall: Legal risk can dominate the conversation and everything becomes a compliance checkbox exercise. Avoid this by emphasizing that legal compliance is the floor, not the ceiling, and the group's goal is building trust, not just avoiding fines.
Product/Technology Representative
Why they're essential: They understand what data is actually being collected, how tracking technologies work, what's technically feasible, and what changes would require significant development resources.
Common pitfall: Technical complexity often shuts down conversation. Avoid this by having the tech representative translate technical concepts into business impact, i.e. "If we implement this, here's what changes for users."
Media/Advertising Representative
Why they're essential: They explain audience strategy, targeting approaches, platform capabilities, and performance implications of privacy restrictions.
Common pitfall: Teams could become defensive about current practices or frame everything as a performance tradeoff. Avoid this by acknowledging that performance matters AND privacy matters; the group exists to find the balance, not to eliminate targeting.
Creative/Content Representative
Why they're essential: They understand messaging strategy and can flag when ad copy or content implies knowledge you shouldn't have about your audience.
Common pitfall: You don't want your team to feel like they're being told to the point that they can't be effective. Avoid this by framing constraints as creative challenges: "How do we connect with this audience without making assumptions about them?"
Extended Members (Strongly Recommended)
Revenue/Fundraising Leadership
They represent business goals and can make final calls when privacy and performance are in tension. Without their voice, the group can become too conservative or disconnected from organizational priorities.
Executive Sponsor
Someone with authority to resolve disputes, allocate resources, and ensure the group's recommendations are actually implemented. This can't be optional—without executive buy-in, the group becomes a discussion club with no power.
Community/Audience Representative (if possible)
Someone who represents the community you serve and can flag when practices might feel intrusive or revealing to your audience. This is especially valuable for organizations serving vulnerable populations.
How to Structure Your Meetings
The cadence and format of your meetings will determine whether the working group becomes valuable or just another calendar obligation.
Size Matters
Aim for 5-8 people maximum in regular meetings. You can bring in subject matter experts for specific topics, but a core group larger than 8 becomes unwieldy. If you need more voices, consider creating sub-working groups that report back to the main group.
Meeting Frequency
When you're getting started: Meet every 2 weeks to build momentum, establish guidelines, and create shared understanding.
Once you're operational: Meet monthly for standing reviews and quarterly for strategic planning.
For urgent issues: Have a process for ad-hoc reviews when campaigns or initiatives need quick privacy assessment.
Rotate Facilitators
Don't let legal always run the meeting. Rotate facilitation across team members to reinforce that this is everyone's responsibility and to prevent any single perspective from dominating.
What Your Working Group Should Produce
A working group that only talks isn't worth the time. You need concrete outputs that guide day-to-day decisions.
1. Privacy Charter
A document that outlines your organization's privacy principles and how they apply to operations. This isn't your legal privacy policy; it's the internal philosophy that guides decisions.
2. Campaign Review Guidelines
Clear criteria for what needs privacy review before launch and what the review process looks like.
3. Targeting Guardrails
Specific rules about what types of behavioral targeting and retargeting are acceptable for your organization.
Example guardrails might include:
- "No retargeting based on visits to crisis support or health resource pages"
- "Lookalike audiences cannot be built from lists of people who disclosed sensitive information"
- "Behavioral targeting on third-party sites is limited to non-sensitive interest categories"
- "All retargeting ads must use generic messaging that doesn't assume knowledge about the viewer"
4. Creative Standards
Guidance for copywriters and designers about messaging that respects privacy.
Standards should address:
- When "you" language is appropriate vs. when it implies assumptions
- How to write inclusive copy that doesn't assume identity characteristics
- Messaging approaches for retargeting that don't reference specific browsing behavior
- How to balance personalization with privacy in email vs. advertising
5. Data Flow Documentation
A living document that maps what data you collect, where it goes, who has access, and how it's used. Remember this is as much about documenting processing activities as much as it is about documenting the systems in which data lives.
6. Vendor Assessment Criteria
Standards for evaluating third-party advertising and data platforms before you sign contracts. This is where having a Data Processing Agreement template is especially important.
Common Pitfalls to Avoid
Making it Legal's responsibility
If legal dominates the conversation, the group becomes a compliance exercise rather than a trust-building initiative. Make sure all voices are heard equally.
Creating bureaucracy without value
If the group becomes a bottleneck or rubber-stamp exercise, people will work around it. Keep the process streamlined and focus on high-impact decisions.
Talking without doing
Discussion without action means nothing changes. Ensure every meeting produces concrete decisions or outputs that guide actual work.
Ignoring business reality
If privacy recommendations consistently ignore performance needs or resource constraints, they won't be implemented. Find the balance, don't just impose restrictions.
Letting the group die quietly
When other priorities take over and meetings get cancelled repeatedly, momentum is lost. Protect the meeting time and treat it as non-negotiable.
The Bottom Line
Privacy working groups succeed when they make everyone's job easier, not harder. They prevent embarrassing campaign failures, reduce legal risk, build audience trust, and create shared understanding so teams aren't constantly second-guessing themselves.
But they only work if they have real authority, produce concrete outputs, and operate with a genuine commitment to balancing privacy with organizational effectiveness.
Start small. Get the right people in the room. Conduct your audit. Create basic guardrails. Build from there.
If you need support launching your privacy working group, facilitating the initial conversations, or developing your charter and guidelines, I offer customized workshops and ongoing consulting to help organizations build these capabilities. Let's talk about what would work for your team.
