Data Privacy Compliance Enablement for a U.S. Entity of a Global Financial Institution

A U.S.-based subsidiary of a major European financial institution faced urgent regulatory pressure to comply with both the General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA). These evolving requirements necessitated structural and procedural changes to the firm’s global data management and privacy approach. The client lacked a mature Data Protection Operating Model, clear data governance procedures, and centralized coordination across Legal, Compliance, IT, Risk, and Operations functions.

Delivery

Our team supported the Data Governance Office in establishing and operationalizing a Data Protection Operating Model that addressed both regulatory requirements and organizational readiness. Drawing on decades of in-house and consulting expertise, our consultants delivered end-to-end support in the following key areas:

• Data Privacy Framework Design: Developed and implemented strategies, policies, and workflows for core privacy functions, including Data Subject Request (DSR) response protocols and integration of privacy-by-design across systems and processes.
• Cross-Functional Governance Alignment: Facilitated structured collaboration with Legal, Compliance, Technology, Risk, and Operations to embed privacy requirements across business functions and system lifecycles.
• Policy and Control Enhancement: Reviewed and uplifted existing data privacy policies and procedures; introduced structured mechanisms for RoPA (Records of Processing Activities), DPIAs (Data Protection Impact Assessments), and defensible policy documentation.
• Audit-Ready Compliance Framework: Enabled Internal Audit to confidently assess privacy controls by delivering comprehensive documentation and evidence aligned with multiple regulatory frameworks including GLBA, OCC guidance, and FFIEC principles.
• Technology Integration: Oversaw the implementation and effectiveness review of privacy-enhancing technologies, automated DSR workflows, and capabilities for structured and unstructured data discovery.
• Training and Awareness: Designed and delivered targeted privacy training to elevate awareness and promote compliance across business and technology teams.
• Inventory and Classification: Created information classification procedures and supported the development of an enterprise-wide personal data inventory.

Value

• Operationalized Regulatory Compliance: Delivered a scalable Data Protection Operating Model aligned with GDPR, CCPA, GLBA, and other U.S. regulatory expectations.
• Audit-Ready Framework: Enabled Internal Audit to assess privacy control effectiveness using well-documented policies, controls, and testing evidence.
• Cross-Functional Awareness and Alignment: Trained business and technology teams on privacy-by-design, improving proactive risk mitigation across the organization.
• Automated Key Processes: Designed automated workflows for handling Data Subject Requests (DSRs), including structured and unstructured data search capabilities.
• Enhanced Governance: Supported a Compliance Risk Management (CRM) framework through clear ownership, control mapping, and risk-tiering for personal data use.
• Cost Avoidance and Risk Reduction: Reduced privacy risk exposure while supporting legal defensibility through consistent documentation and regulatory alignment.