Privacy Technology Enablement at a Regional Utility Provider
How we helped a utility provider serving 3.5 million customers modernize their privacy program while maintaining operational continuity.
Client Overview
A regional utility provider serving over 3.5 million electricity and water customers sought to modernize its data privacy program in response to growing regulatory expectations and internal digital transformation initiatives. As a highly regulated infrastructure organization, the client needed to ensure privacy compliance while maintaining operational continuity and stakeholder trust.
Business Challenges
The utility's decentralized operations and aging systems created a fragmented privacy landscape:
- No mechanism to manage cookie consent across digital touchpoints
- Manual and delayed DSAR fulfillment due to disconnected business systems
- Limited visibility into personal data locations, usage, and system flows
- PTA and PIA activities were inconsistent and lacked formal triggers
- Privacy ownership and accountability were unclear across business and IT units
Approach & Solution
The project was executed through a phased, domain-specific implementation model, with change management integrated continuously across all privacy workstreams to ensure adoption and operational alignment.
Consent & Cookie Governance
- Enabled cookie consent banners and opt-out mechanisms across web, mobile, and authenticated portals
- Developed a cookie categorization framework and compliance monitoring dashboard
Change Management Embedded:
- •Collaborated with marketing and digital teams through guided workshops
- •Developed governance SOPs and knowledge articles for ongoing management
Data Mapping, Discovery & Cataloging
- Conducted automated and manual data discovery across cloud, on-prem, and legacy systems
- Developed a unified data mapping model covering customer, employee, and operational data
- Tagged high-risk data types (e.g., utility usage, financials, geolocation, medical accommodations) and documented data flows between 800+ systems and databases
- Created a searchable privacy data catalog with system owners and processing purposes
Change Management Embedded:
- •Partnered with IT, data governance, and cybersecurity to validate mapping and define ownership
- •Established ongoing data review checkpoints as part of IT change management processes
Privacy Impact Assessment (PTA / PIA) Lifecycle
- Designed dynamic PTA and PIA templates tailored to system, project, and procurement types
- Embedded privacy assessments into existing project intake, contract approval, and change request workflows
- Created scoring logic to flag sensitive data types, third-party involvement, and high-risk use cases
Change Management Embedded:
- •Delivered department-specific training for project managers, procurement, and legal staff
- •Developed real-time dashboards for assessment status, volume, and risk trends
Data Subject Access Requests (DSAR)
- Centralized DSAR intake via a unified workflow for consumers and employees
- Automated record retrieval and redaction processes for core data systems
- Integrated validation, routing, and escalation protocols to meet regulatory deadlines
Change Management Embedded:
- •Rolled out role-specific training for legal, customer service, and technical teams
- •Built internal guidance center and escalation directory to support consistent response
Results
- Reduced DSAR fulfillment time from 26 days to under 5 days on average
- Mapped and documented over 800 systems and databases handling personal and operational data
- Achieved a 3x increase in proactive PIAs initiated before go-live or procurement
- Established cookie consent compliance across all digital interfaces
- Enabled organization-wide visibility into data flows, ownership, and privacy obligations
- Internal teams demonstrated sustained engagement and accountability across legal, IT, and operations
Key Takeaway
True privacy enablement in complex enterprises requires more than tools. It demands a cross-functional commitment to operational change, process integration, and sustained ownership—starting with clear data visibility and supported by embedded change management at every stage.
Project Details
Client
Regional Utility Provider
Industry
Utilities / Energy
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