How Scale-Ups Can Get Privacy Right: Lessons from 100’s of Privacy Audits

For scaling businesses, privacy is often on the radar, and they want to get it right, but it’s not always clear what “getting it right” actually looks like in practice, or where to even begin.

A good place to start is understanding where you are today, and that’s where a Privacy Audit comes in.

After conducting hundreds of Privacy Audits for some of the world’s most exciting scale‑ups, Trust Keith has seen the patterns first‑hand: what works, what sticks, and what makes privacy an embedded part of how great businesses operate.

In this blog, we’re sharing those lessons, along with practical advice on how your business can get privacy right without slowing down your growth.

What’s a Privacy Audit and How Does It Work?

A Privacy Audit is an evaluation of your current data protection programme and posture.

It gives you a clear, structured view of how your programme is really performing, and helps you understand where the risks are, what’s working well, and where to focus next.

At Trust Keith, our audits are built around 48 weighted controls covering everything from governance, policies, and training to breach response, vendor management, and data mapping. These controls are grounded in the ICO’s Accountability Framework, ISO 27001 principles, and insights from hundreds of real-world compliance reviews.

Your results are summarised into a single score out of 800, which gives you a clear indication of how strong your privacy programme is at a glance. 

With the audit you’ll see a breakdown of where your organisation is performing well, where the gaps are, and which areas need the most attention.

The Most Common Privacy Pitfalls 

After carrying out hundred of audits, we’ve seen the same issues appear again and again:

Staff often don’t know what a breach looks like, how serious it might be, or who to report it to. If something went wrong today, would your team know what to do?

The solution: Establish a documented breach response process that’s easy to follow and tailored to your organisation. Include guidance on what qualifies as a breach, who to notify, how to assess the risk, and when to escalate.


2. Most privacy programs aren’t risk-driven

Many companies treat “data protection” as a single line item in their business risk register - or worse, have no risk register at all. The result is reactive, box-ticking compliance.

The solution: build a dedicated privacy risk register, break down your specific privacy risks, and prioritise program activities based on what poses the greatest threat to your business.


3. No clear ownership

In many businesses, privacy is either treated as a side responsibility or something that “everyone owns”, which often means no one really does. Without clear ownership, things slip through the cracks, and there’s no one driving progress or taking accountability.

4. Policies that don’t reflect reality

Privacy notices and internal policies are often outdated or copied from templates that don’t reflect how the business actually uses data.

5. Training is a one-time event

It’s common for employees to take awareness training courses when they join, if at all, and then never again. But tools, processes, and risks evolve. Training needs to keep up.

The solution: Make training regular and engaging. Refresh it at least annually, and make sure it’s relevant to how your teams actually work.


6. Lack of visibility over personal data

Few companies can clearly say what data they collect, where it’s stored, how long they retain it, and who they share it with. This makes even simple data protection requests painful to handle.

The solution: Keep an up-to-date data map that shows what personal data you collect, where it lives, who you share it with, and how long you keep it. It’s a practical way to stay on top of requests, reviews, and risks.

These issues are often symptoms of a wider problem: privacy isn’t integrated into day-to-day operations. It’s seen as separate, until it’s too late.

What “Good” Privacy Looks Like

The reality is, data privacy is a cultural problem with a cultural solution. It’s not just about having the right policies or completing a checklist, it’s about embedding privacy into how your team thinks, works, and makes decisions.

That doesn’t mean turning everyone into a compliance expert. It means giving people the clarity, training, and processes they need to handle data responsibly in the flow of their actual work.

So where should you start?

• Link privacy to outcomes your employees care about: it helps Sales win enterprise deals, Finance lower insurance premiums, HR build trust and a stronger employer brand, etc. Otherwise, it becomes a box-ticking exercise.
  
  
• Privacy by design and default. New projects and tools should be assessed for data protection impact at the outset, not after they’ve launched. Risk should be built into planning, not treated as an afterthought.
  
• Leadership buy-in. Senior leaders should understand privacy as a strategic risk. They should give it space in board meetings, connect it to trust and growth, and not treat it as a side project for legal or ops.
  
  
• Prioritisation based on risk. No one can do everything at once. The best teams focus on what matters most - high-risk data flows, critical vendors, common failure points - and build from there.
  
  
• Make ownership clear and visible. People know what to do. Who to go to. Where the documents live. There’s no ambiguity, and privacy isn’t something to avoid or fear, it’s just part of how work gets done.
  
  
• Progress you can measure. A real-time audit score gives you a clear, realistic view of where your privacy programme stands right now. It highlights what’s working, where the gaps are, and helps you focus on what needs attention, so you can track progress over time.

How To Make Your Privacy Programme Sustainable

Too often, companies tackle privacy as a one-off project, triggered by a due diligence request or a compliance scare. They produce a flurry of policies, maybe even score well on an audit… and then do nothing for 12 months.

That approach doesn’t work. Sustainable privacy means making it part of the business rhythm. 

Here are a few simple ways to make it stick:

• Quarterly risk reviews. Whether it’s a formal committee or a recurring check-in, there should be a regular touchpoint to revisit privacy-related risks, updates, and priorities.
  
  
• Refresher training. Annual training is a minimum. For higher-risk teams like product, marketing or customer support, more tailored sessions go a long way. Training doesn’t have to be boring, it should be relevant, engaging, and grounded in real-world examples.
  
  
• Simulated incidents. A “fake” breach (e.g. a deliberate mis-send or roleplay) helps test your processes and gives teams real confidence about how to respond under pressure.
  
  
• Decentralised responsibility. Privacy isn’t one person’s job. Product owns DPIAs. Ops handles vendor reviews. Marketing manages consent. The privacy lead keeps the whole thing connected, but every team has a role.
  
  

You Don’t Need to Be Perfect, You Need to Be Proactive

Privacy isn’t static. Laws change. Customer expectations evolve. And internal risk grows as your business scales.

The best companies aren’t the ones that get everything right immediately. They’re the ones that are aware of their gaps, take action, and make privacy a repeatable part of how they operate.

That starts with understanding where you are now, and what matters most next.

Want to Know How Your Privacy Programme Really Measures Up?

At Trust Keith, we’ve helped hundreds of businesses assess and strengthen their data protection programmes, often starting with a simple conversation.

We’ll help you make sense of where things stand, how our audit works, and how it can help you get on track to getting privacy right.