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If your company has a GRC tool or even just a particularly tricked out spreadsheet, you might think you have a gorgeous privacy dashboard. Whether it’s pretty, however, is much less important than whether it gives you the data you need to know whether your program will survive an incident, an audit, or a key customer security review.
This is the privacy KPI trap. Does your organization measure what is easy to count (trainings delivered, policies published) instead of what predicts readiness (handoff speed, evidence freshness, vendor coverage, request throughput)?
Good privacy metrics are about knowing where you are fragile and whether the program is improving.
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What useful privacy metrics do
A useful metric answers a real question leaders ask, such as:
Are we honoring rights?
Are we controlling vendors?
Are we catching risk before launch?
Are we ready to respond when something breaks?
If your metric does not change decisions, it is probably a vanity metric.
Three categories of metrics that actually matter
You only need 6-10 key metrics that map to your major risks and your operating model to have a functional privacy dashboard. Look for metrics like the following:
Throughput and timeliness (DSR SLA performance, PIA cycle time, vendor review cycle time)
Coverage (percent of critical vendors with current diligence, percent of systems mapped in inventory, percent of high-risk features with PIAs)
Readiness and evidence (tabletops run, evidence freshness, decision logs completed, time to assemble incident team)
Define metrics like an engineer
Fuzzy metrics aren’t data. The definition of the metric and how to arrive at it need to be concrete. If two people can compute the metric differently, the metric is not ready for leadership.
For each KPI, define:
Exact calculation method (what counts, what does not)
Data source (which register or system provides the input)
Owner (who maintains and validates the number)
Thresholds (what is 'good', 'watch', 'bad')
Caveats (what the metric cannot tell you)
Translate ops signal into board language
Your board or executive committee does not need (and almost assuredly does not want) the raw numbers. They want you to tell them a story about what is improving, what is risky, and what you are doing about it.
A simple board-friendly structure is: (1) trend, (2) root cause, (3) remediation plan, and (4) next checkpoint. Short, to the point, and concrete. It’s that adage… when you bring your boss a problem, come prepared with a solution for it.
This is also why metrics should pull from registers you already maintain (DSR log, vendor register, PIA register, evidence index). If you must create a separate reporting universe, the dashboard will die because no one will keep up after it, like that orchid your husband bought you for Valentine’s Day that you promptly forgot about (I swear, this isn’t a personal story…).
Avoid the two KPI failure modes
There are two KPI failure modes, and they are:
Metric sprawl: too many metrics, no focus, no action.
Metric theater: metrics that make the program look good but do not reflect operational reality.
The fix for both problems is ruthless prioritization. Pick metrics tied to risk and readiness, not activity. Below you will find our micro tool, a KPI Definition Card Pack that helps you define and establish those actionable KPIs.
Become a paid subscriber to get access to all of the mini tools that we publish with each post. For instance, this post includes an KPI Definition Card Pack.
Finally, reminder that the opinions expressed in this article are the opinion of The Privacy Design Lab. They are not legal advice, and no attorney-client relationship is formed by reading this article or downloading the KPI Definition Card Pack. If you need to consult legal counsel, you can book a consult with ARLA Strategies or other legal counsel you trust!
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