Case Study: Countywide Privacy Program Strategy for a Large U.S. Government Entity

Background

A large U.S. county government—comprising over 35 departments—was responsible for delivering services to millions of residents, many of whom are members of vulnerable or underserved populations. While the agency had a designated Office of Privacy, privacy practices varied widely across departments. There was no formalized countywide governance, and privacy policies, assessments, and documentation efforts lacked consistency.

Challenge

• Disparate privacy policies and procedures across departments
• No standard process for Privacy Impact Assessments (PIAs) or vendor privacy reviews
• Absence of a central privacy governance structure or oversight body
• Inconsistent use of data mapping, retention, and incident response practices
• Limited visibility into departmental privacy maturity and gaps

Solution

A comprehensive privacy program development engagement was led to deliver both centralized strategy and department-specific support. To accommodate the structure of the county, a federated governance model was implemented—empowering departments to manage their own operations while aligning to minimum privacy requirements and guardrails established at the countywide level. Key activities included:

• Reviewing and synthesizing privacy-related documentation from 30+ departments
• Delivering a Countywide Privacy Program Summary Report highlighting key trends, leading practices, and capability gaps
• Creating a centralized privacy roadmap with department-level milestones to support phased rollout
• Defining a federated privacy governance framework with:
  • •A shared vision and minimum standards for all departments
  • •Department-specific flexibility to implement controls tailored to their data and systems
• Designing the structure and charter for a cross-departmental privacy governance committee
• Developing implementation playbooks for:
  • •Privacy by Design integration
  • •Vendor privacy risk and third-party due diligence
  • •Data retention and disposal for PI, PII, and PHI
  • •Incident response coordination and escalation pathways
• Building a dynamic Power BI dashboard to help leadership track program maturity, compliance metrics, and roadmap progress

Outcomes

• Established a unified privacy vision with buy-in from executive leadership and departmental stakeholders
• Created a scalable, federated governance model that respects departmental autonomy while ensuring baseline compliance
• Delivered a countywide privacy roadmap aligned with CCPA, HIPAA, GDPR, and emerging AI/data regulations
• Developed reusable privacy templates, workflows, and tools to sustain adoption
• Transitioned the agency from reactive privacy operations to a proactive, programmatic model

Takeaway

Public-sector complexity doesn't have to slow down progress. With the right structure, support, and strategic alignment, even highly decentralized organizations can mature privacy operations and embed sustainable governance at scale.