Identifying Practical Challenges in the Implementation of Technical Measures for Data Privacy Compliance

TL;DR

This paper identifies 33 practical challenges in implementing technical measures for data privacy compliance, highlighting issues from vague regulations to organizational factors, based on interviews and surveys with privacy professionals.

Contribution

It provides a comprehensive list of challenges and insights into the practical difficulties faced during privacy measure implementation, which were previously underexplored.

Findings

33 challenges identified in privacy measure implementation

Challenges span technical, organizational, and regulatory aspects

Implications for improving privacy compliance practices

Abstract

Modern privacy regulations provide a strict mandate for data processing entities to implement appropriate technical measures to demonstrate compliance. In practice, determining what measures are indeed "appropriate" is not trivial, particularly in light of vague guidelines provided by privacy regulations. To exacerbate the issue, challenges arise not only in the implementation of the technical measures themselves, but also in a variety of factors involving the roles, processes, decisions, and culture surrounding the pursuit of privacy compliance. In this paper, we present 33 challenges faced in the implementation of technical measures for privacy compliance, derived from a qualitative analysis of 16 interviews with privacy professionals. In addition, we evaluate the interview findings in a survey study, which gives way to a discussion of the identified challenges and their implications.