Privacy at Series B: A Practical Guide for Scale-Ups

When scale-ups hit Series B, privacy and data protection can’t sit on the sidelines.

You’re growing fast - more customers, more data, more complexity, and facing increased scrutiny from customers, investors, and regulators.

This guide brings together practical lessons from real operators who have scaled fast, including Trust Keith’s own customers and privacy experts.

We’ve turned their honest reflections - what worked, what didn’t, and what they’d do differently - into clear frameworks and actionable steps you can take to get privacy right at this critical point.

Contents

• Why Series B Raises Privacy and Compliance Risks
• 5 Essential Privacy Steps for Scale-Ups at Series B
• Privacy Checklist for Growing Companies at Series B
• Lessons From the Experts
• The Path to Privacy Success at Series B
  
  

Why Series B Raises Privacy and Compliance Risks

At Series B, it’s not enough to show growth,  you need to show you’re ready to scale responsibly. Investors and customers want to see not just momentum, but maturity. And that puts privacy and data protection front and centre.

Here’s why:

• Investors expect more maturity. Privacy is now part of operational due diligence. They want to see real systems in place, not just good intentions.
• Regulatory expectations increase. By Series B, regulators expect foundational privacy controls to be documented, operationalised, and regularly reviewed.
• Customers start asking harder questions. Especially in regulated sectors like health, finance, and education. They want to see Data Protection Impact Assessments (DPIAs), Data Subject Request (DSR) processes, retention rules - not just a polished privacy policy.
• The stakes go up. More tools, more integrations, more data. You’re processing sensitive information, and one misstep can break trust or trigger regulatory scrutiny.
• Early-stage shortcuts stop working. Manual workarounds, scattered ownership, informal processes - they don’t scale. What felt fine at Seed or Series A starts to slow you down.

Done right, privacy becomes a growth enabler. But do it wrong, and it soon becomes a blocker.

5 Essential Privacy Steps for Scale-Ups at Series B

1. Assigning Privacy Ownership

In most startups, privacy gets passed around like a hot potato. But at Series B you need a clear privacy lead - someone who owns decisions, drives progress, and keeps things joined up.

They don’t need to be a full-time DPO from day one, but they do need:

• Well defined responsibilities (see the ICO's spec)
• An engaged leadership team 
• Actual bandwidth, not just the title
• Expertise in data protection

💡 Top Tip: Assign a single privacy owner, even if part-time. Make them the bridge across departments. In around 60% of organisations, ownership sits with ops.

2. Cross-Functional Privacy Teams

Privacy isn’t just one person's job. Legal might set the standards, but it’s ops that implements them, product that collects the data, engineering that stores it, and customer success that explains it.

If only one function is involved, privacy becomes siloed and fragile.

To make privacy stick, connect it to each team’s goals, and focus where the risk is highest. If people understand why it matters to their work, they’re far more likely to take ownership.

• Involve Product in DPIAs and data flows
• Train engineering on minimisation, retention, and breach response
• Loop in ops and CS on handling data requests
• Make sure everyone understands what counts as “personal data” in your world

💡 Top Tip: Build privacy into existing processes, like adding sign-offs to product planning or vendor onboarding.

3. Scalable Privacy Processes

At Series B, documentation starts to matter, but building repeatable privacy frameworks for scale-ups matters even more. If key tasks like DPIAs, third-party reviews, or DSRs rely on memory, manual work, or scattered docs, they won’t scale.

Generic template policies look good on paper but fall apart in practice. You need to build proportionate, tailored workflows that your team will follow.

Instead of firefighting, build:

• DPIA templates that are baked into your product development process
• Vendor reviews with clear privacy triggers (e.g. PII, third-country transfers)
• DSR handling that’s documented, repeatable, and not reliant on a single person
• Policies that are version-controlled and easy to find, not buried on someone’s desktop

💡 Top Tip: Start small, but build structure. Replace ad hoc documents with flows your team can follow without thinking twice.

4. Balancing Privacy Compliance with Practical, Scalable Processes

It’s easy to get stuck in a compliance rabbit hole - trying to draft the perfect policy, cover every edge case, or replicate enterprise frameworks. The result? A privacy setup that’s technically correct but totally unusable.

The best scale-ups:

• Focus on relevance, not legalese
• Write policies and processes in plain language, with clear owners and next steps
• Build just enough structure to give people confidence, without adding friction
• Adapt tools to how teams already work (e.g. Notion, Google Drive, Jira) rather than making them learn a new system just for privacy

A 40-page policy no one reads is a waste. A 4-step DPIA process built into a Notion page your team actually uses? That’s value.

💡 Top Tip: Prioritise usefulness over completeness. Every privacy control you create should be accessible, actionable, and used.

5. Preparing for Customer, Investor and Regulatory Privacy Reviews

As your deals grow in size and complexity, so do expectations. You’ll start getting asked privacy and security questions you may not have faced before. 

Privacy Checklist for Growing Companies at Series B

Customers, investors and regulators will want to see:

1. Data access request handling – How you respond to DSRs
2. Third-party vendor management – Which providers you use and how you vet them
3. Data storage and access controls – Where data lives, who can access it, and retention rules
4. Breach detection and response – How you identify, escalate, and resolve incidents
5. Documented privacy policies – Accessible, plain-language policies that reflect reality, not theory

If your team can’t explain these processes in plain English, neither can you. That’s why the best scale-ups don’t just publish policies, they train their people to demonstrate compliance with confidence.

💡 Top tip: Think beyond the policy page. If your team can’t explain how things work, neither can you.

Lessons From the Experts

Privacy looks different at every scale-up, but one thing’s consistent: it becomes a lot more strategic once growth kicks in.

Our customers, along with one of Trust Keith’s expert DPOs, have shared real-life lessons on what it takes to get privacy right at this stage: what worked, what didn’t, and what they’d do differently.

Make Privacy Part of Operational Excellence

As your company matures, your privacy posture needs to mature with it. For high-growth businesses moving into new markets or enterprise deals, the bar rises fast - and being able to respond to privacy questions with clarity and confidence becomes essential.

“As we grew, we started getting deeper privacy questions - not just from regulators, but from customers too. We wanted to be able to respond with confidence and clarity.”

- Al Patel, Head of Operations at bioniq

The shift isn’t always about fixing what’s broken. Sometimes it’s about formalising what’s already working, and making it repeatable. 

Aligning your internal processes with external expectations builds trust, smooths procurement, and shows you’re ready to scale responsibly.

Build Privacy That Teams Actually Use

Privacy can’t live in legal alone. For it to work, it needs to be simple, accessible, and embedded into how the rest of the business operates.

“We knew the legal expectations, but the real unlock was translating that into tools the business could engage with.”

Emilie Proudlove, Legal & Compliance Operations Lead

Make privacy usable. That means ditching dense documentation and replacing it with lightweight, flexible workflows that reflect how your teams already work - from DPIAs to vendor onboarding.

If privacy lives in a silo, it gets ignored. But when it’s built into product, engineering, and ops workflows, it becomes part of the culture - not a hurdle.

• Keep privacy tools simple, visible, and accessible
• Build processes that support fast-moving teams, not slow them down
• Prioritise alignment over enforcement. Shared goals get better engagement
• Make sure documentation reflects reality, not just ideal processes

Start with Structure, Not Scale

You don’t need a heavyweight privacy program on day one. What you need is structure: clear ownership, simple workflows, and a setup that fits your stage of growth.

Fast-growing companies often try to do everything at once - complex tooling, detailed policies, full documentation. But more doesn’t always mean better. Start small, stay clear, and build forward.

Focus on the things that matter most:

• Know who’s responsible
• Understand your key risks
• Map where your data is and how it flows

Privacy should be part of the culture. That means shared ownership, simple guidance, and practical processes that slot into how teams already work. When privacy is built into everyday decisions, it becomes second nature - not just a checkbox.

“Data protection is people protection.”

“Privacy is a cultural problem with a cultural solution.”

- Kayleigh Logan-Cleghorn, Lead DPO at Trust Keith

And when that happens, privacy stops being reactive and overwhelming. It becomes part of how the business runs - clear, repeatable, and built to scale.

The Path to Privacy Success at Series B

Privacy at Series B isn’t about perfection, it’s about building a structure that supports growth.

Most teams already take data protection seriously, but as the business scales, so do the risks: more tools, more data, more scrutiny. Without clear ownership and simple, repeatable processes, things can unravel fast. Put the right foundations in place now, and privacy becomes a strength.

At Trust Keith, we work with scale-ups who want privacy frameworks to be an accelerator, not an afterthought. Whether you’re formalising what’s already working or getting ready for your next raise, now’s the time to get it right - and set your business up to scale with confidence.

Want to find out more? Have a chat with one of our experts today.

About Trust Keith

Trust Keith is your always-on privacy partner, helping fast-moving scale-ups stay compliant with global data protection regulations in a way that’s practical and built to scale.

With a dedicated Data Protection Officer (DPO) embedded in your team and our intelligent Privacy Management Platform doing the heavy lifting, we deliver privacy frameworks for scale-ups that unlock enterprise deals, accelerate fundraising, and make compliance a growth enabler, not a blocker.