Focus area · PRV

Data-privacy exposure, measured against enforcement reality

Privacy law looks similar on paper in many countries and differs sharply in practice. We show which authorities enforce, what they fine and where your data flows meet the strictest regimes.

01PRV

Same rules, different enforcement

Privacy risk is driven by three things: the regime, the authority's enforcement appetite and your processing. The GDPR sets one standard across the EU, yet fine levels and priorities vary widely between authorities. Outside the EU, regimes range from GDPR-style laws to data-localisation and state-access rules.

This focus area covers legal and regulatory compliance risk. Information security and cyber risk are outside our scope.

02Frameworks

Legal frameworks we map

We map the regimes that apply to your footprint. Typical anchors:

GDPR
Regulation (EU) 2016/679, with fines of up to 4 % of worldwide annual turnover (Art. 83), enforced by national data-protection authorities and coordinated through the European Data Protection Board.
Germany: BDSG and state authorities
The Federal Data Protection Act and the supervisory authorities of the federal states, with employee data as a recurring focus.
International data transfers
Chapter V GDPR: adequacy decisions including the EU-US Data Privacy Framework, standard contractual clauses and transfer impact assessments.
National privacy laws
For example Brazil's LGPD, China's PIPL, India's DPDP Act and US state laws such as the CCPA, mapped for each country in scope.
Data localisation and state access
Requirements to store data locally or grant authorities access, which can conflict with GDPR obligations.

This is a risk analysis, not legal advice. Where a finding raises a legal question, we say so and you take it to counsel.

03Scope

What we look at

EXT

External analysis

Your exposure as the outside world sees it.

  • Enforcement record and fine levels of the data-protection authority in each country
  • Privacy cases in your sector and at your direct competitors
  • Transfer regime and adequacy status per country
  • Localisation and state-access requirements
INT

Internal analysis (under NDA)

Your exposure as your own data shows it.

  • Categories of personal data and processing per country
  • Cross-border data flows and transfer mechanisms in use
  • Internal incidents, complaints and authority enquiries
  • Employee monitoring and the use of personal data in investigations and whistleblowing
Coverage7 areas × 9 source types

Seven focus areas, mapped against every source we read.

Indicative coverage matrix: seven focus areas against external and internal source types.
Module 1 · External analysisModule 2 · Internal analysis (NDA)
Focus areaLaw & regulationEnforcement recordSector casesCompetitor casesIndicatorsInternal casesBusiness partnersSponsoring, donations, membershipsGifts & hospitality
ABCAnti-bribery & corruptionCore sourceCore sourceCore sourceCore sourceCore sourceCore sourceCore sourceCore sourceCore source
AMLAnti-money launderingCore sourceCore sourceCore sourceCore sourceCore sourceCore sourceCore sourceWhere relevantNot used
ATRAntitrust & competitionCore sourceCore sourceCore sourceCore sourceWhere relevantCore sourceWhere relevantCore sourceWhere relevant
FRDFraudCore sourceCore sourceCore sourceCore sourceWhere relevantCore sourceCore sourceWhere relevantWhere relevant
PRVData privacyCore sourceCore sourceCore sourceCore sourceWhere relevantCore sourceWhere relevantNot usedNot used
EXCExport control & sanctionsCore sourceCore sourceCore sourceCore sourceWhere relevantCore sourceCore sourceNot usedNot used
HRTHuman rightsCore sourceCore sourceCore sourceCore sourceWhere relevantCore sourceCore sourceWhere relevantNot used
Core sourceWhere relevantNot usedIndicative mapping — fixed per engagement in the proposal

Highlighted row: PRV · Data privacy

04Red flags

Typical red flags

  • Transfers to countries without an adequacy decision and without a documented transfer assessment
  • Employee monitoring or background checks in jurisdictions with strict employment-privacy rules
  • Marketing based on purchased or enriched contact data
  • Health, financial or children's data in core processes
  • Authorities with a record of high fines in your sector
  • Localisation requirements in markets where you run central systems
05Sources

Sources

  • Decisions and fines published by data-protection authorities and the EDPB
  • Court judgments, including the Court of Justice of the EU
  • Third-party enforcement trackers, cross-checked against the authority's own publication
  • Statutes and official guidance per country
  • No single index: there is no reliable composite measure of privacy enforcement, so we read the record directly

Every finding in the report carries its source and date.

06Sectors

Typically exposed sectors

Exposure tends to be higher where processing of sensitive or large-scale personal data is core to the business: healthcare, financial services and insurance, telecoms, technology platforms, consumer retail and media.

  • Healthcare services
  • Pharma & life sciences
  • Medical devices
  • Financial services – banking
  • Insurance
  • Payments & fintech
  • Telecommunications
  • Technology & software
  • Consumer goods & retail
  • Media & entertainment

A tendency, not a rating. Your actual exposure depends on business model, customer mix and footprint.

07Deliverable

In your deliverable

  • PDF: a data-privacy chapter with regime overview, enforcement picture per authority, sector and competitor cases, red flags and recommended measures
  • Heatmap row per country × sector with the likelihood × impact rating
  • XLSX: case register (authority, year, company, violation, fine, source), transfer-regime table and scoring sheet
  • With the internal module: your data flows set against the enforcement picture
FAQ2 questions

Questions on data privacy

Do you assess our IT security?

No. Cybersecurity is outside our scope. We cover the legal and regulatory side: which rules apply, how they are enforced and where your processing creates exposure.

How does this relate to the work of our data-protection officer?

It complements it. The data-protection officer advises and monitors; we provide an external, source-backed view of enforcement risk across countries that the officer and Compliance can both use.

Next step

See where privacy enforcement could reach you.

Tell us your countries, sectors and main data flows. We come back with a scope proposal.