Privacy Report ISACA in Practice
Privacy Report ISACA in Practice
CONTENTS
3 Abstract
4 Executive Summary
4 / Key Findings
4 Survey Methodology
6
9 / Skill Gaps
10 Privacy Budgets
10
12 / Privacy Team Interaction With Other Areas
13 / Boards of Directors’ Privacy Involvement
13 / Monitoring Privacy Programs
14
16
16
18
20
21
ABSTRACT
Privacy in Practice 2023 reports the results of the ISACA® global State of Privacy Survey,
program trends, awareness training and breaches, and privacy by design. Some survey
Executive Summary
Privacy in Practice 2023 • Experience is considered the most important factor in
budgets, programs, awareness training and privacy by
design, based on the results of the ISACA global State of
• The demand for privacy professionals is expected
Privacy Survey, conducted in the fourth quarter of 2022.
to increase over the next year for technical privacy
Strong enterprise privacy practices are critical in a rapidly professionals and legal/compliance privacy
evolving privacy regulatory landscape. Privacy violations professionals.
erode customer trust and increasingly result in enterprise • Privacy teams interact most frequently with
information security, legal/compliance and risk
programs that aim to protect data subjects and gain their management teams.
trust set their enterprises apart from competitors. This
• Enterprises that practice privacy by design are more
white paper explores the state of organizational privacy.
are impacted by staff shortages. • Use more privacy controls overall than are legally
• required
than legal/compliance privacy roles to have increased • Feel their privacy budget is appropriately funded
demand in the next year.
Survey Methodology
In the fourth quarter of 2022, ISACA sent survey
invitations globally to approximately 46,000 ISACA
constituents who hold the ISACA CSX Cybersecurity
Information Systems Auditor® ®
34%
Top industries Years of experience Total revenue
24%
14% 8%
24%
Technology services/ 21%
consulting 14%
23% 16%
19% 13%
24%
12%
Financial/banking
1–5 16–20
13%
6–10 21–25
Less than $50M– $100M– $500M– Greater
Government/military– 11–15 25+ $50M $99M $499M $999M than $1B
national/state/local
Region Europe
20% Asia
19%
North America 47%
4%
4%
Africa
Middle East
FIGURE
What 2: Staff Privacy
percentage of your Roles
staff are in the following roles?
What percentage of your staff are in the following roles?
Technical IT staff 8%
(excluding security professionals)
37%
21%
14%
10%
6%
4%
Risk professionals 8%
51%
18%
8%
5%
5%
4%
Security professionals 4%
45%
19%
11%
7%
10%
4%
Both legal/compliance and technical privacy teams are more compared to last year and/or increasing privacy
understaffed, according to the ISACA survey results. budgets—35 percent of last year’s survey respondents
Forty-four percent of respondents indicate that legal/ reported that their privacy budget would increase in the
next 12 months.
understaffed, and 53 percent of respondents report that
Some enterprises are taking steps to address
teams than in legal/compliance teams is consistent with say that their enterprises have open legal/compliance
privacy positions, and 34 percent indicate they have
FIGURE 3:
Understaffing of Privacy Roles
Legal/compliance 46%
44%
2022 2023
On average, how long does it take to fill legal/compliance On average, how long does it take to fill technical privacy
privacy positions with a qualified candidate? positions with a qualified candidate?
2% 2%
10% 9%
22% 23%
20%
24%
2%
26% 25%
2% 18%
15%
1–3 months Cannot fill open positions 1–3 months Cannot fill open positions
Although some survey respondents report that the somewhat increased and 30 percent indicating it stayed
the same.
FIGURE 6:
How important are each of the following factors in determining if a privacy candidate is qualified?
Very important Somewhat important Not very important Not at all important
According to 76 percent of ISACA survey respondents, the laws and regulations to which an enterprise is subject
Skill Gaps •
Survey respondents identify a lack of experience with
•
different types of technologies and/or applications as
the biggest skill gap in current privacy professionals
• Networking and/or other infrastructure knowledge
•
Fifty-four percent of respondents report that experience
with frameworks and/or controls is a large skill gap. The Enterprises are working to reduce these skill gaps. Figure 7
shows the solutions that enterprises are applying.
Which, if any, of the following has your organization undertaken to help decrease this privacy skills gap?
Select
Which, all thatof
if any, apply.
the following has your organization undertaken to help decrease this privacy skills gap? Select all that apply.
Increased use of
performance-based training 25%
to attest to actual skill mastery
Increased reliance on
credentials to attest to actual 25%
subject matter expertise
Organization has no
privacy skills gap 4%
Other 1%
Privacy Budgets
decreased slightly to 34 percent—from 35 percent
face. Forty-two percent of ISACA survey respondents last year—that decrease may be due to the increased
report that their enterprise privacy budget is somewhat or percentage of respondents who believe that their privacy
budget is appropriately funded and therefore may not see
a need to increase funding.
overfunded and 14 percent do not know. This is a
slight improvement from last year, when 45 percent of
respondents felt their privacy budget was underfunded,
and a larger improvement from 2021, when 49 percent
of survey respondents believed their privacy budget
was underfunded.
accountable for privacy, and 14 percent say the executive- a privacy program, and 38 percent of respondents say
Who is primarily
Who is primarily accountable
accountable for
for privacy
privacy in
in your
yourorganization?
organization?
Board of directors 5%
Don't know 4%
Other 4%
Which, if any, of the following are obstacles faced by an organization in its ability to form a privacy program?
Select
Which, all thatof
if any, apply.
the following are obstacles faced by an organization in its ability to form a privacy program?
Select all that apply.
No obstacles exist 7%
Don't know 9%
Other 1%
meet with legal/compliance privacy professionals privacy considerations exist throughout the enterprise.
Another 17 percent of respondents report that their and development, procurement, internal audit, human
FIGURE 10:
How often do technical privacy professionals meet with legal/compliance professionals to understand legal
and regulatory requirements?
How often do technical privacy professionals meet with legal/compliance professionals to understand legal and
regulatory requirements?
6%
17%
Never Monthly
25%
7%
1–2 times per year Weekly
28%
Do you think your board of directors views your enterprise’s privacy program as:
A combination of both
14%
Perform a privacy
impact assessment (PIA) 45%
No monitoring is performed
9%
Don't know
11%
Other 1%
Annually 65%
Quarterly 17%
Don’t know 6%
Other 2%
and revise training as new laws and regulations go into Most respondents believe that privacy training
four percent do not revise their privacy training. of respondents say that privacy training and awareness
programs have a strong positive impact, and 47 percent
say they have some positive impact.
awareness training, enterprises should monitor their
training programs. shows the metrics that
respondent enterprises use to evaluate privacy training
program effectiveness.
What metrics does your organization track to evaluate the privacy training program’s effectiveness?
Select all that does
What metrics apply.your organization track to evaluate the privacy training program’s effectiveness? Select all that apply.
Other 6%
•
techniques—Code of practice for information security
Unsurprisingly, regional variations exist for the frameworks A previous section in this report revealed that privacy
and regulations used to manage privacy. Seventy-nine budgets appear to be more adequately funded this
percent of European respondents use GDPR. It may be year than last year, and understaffing seems to be
surprising that only 79 percent of respondents in Europe improving. Part of the reason for this may be that
use GDPR, but this may be partially attributable to Brexit. enterprises felt the strain on their privacy teams and
Sixty-one percent of respondents in the United States use increased privacy budgets and staff sizes accordingly.
the NIST Privacy Framework. This strain may be caused partially by an increase
in data-subject requests. Thirty-four percent of
Given the myriad privacy laws and regulations in effect, respondents say that the number of data-subject
some enterprises struggle to identify and understand requests has somewhat or significantly increased.
their privacy obligations. Twenty-three percent of
Only 11 percent of respondents report that their they know a security incident occurred but are unsure
enterprise experienced a material privacy breach in the if personal information was compromised. Dwell time
past 12 months, which is slightly higher than last year
that their enterprise did not have a privacy breach, 17 so many respondents do not know if a privacy
percent do not know and nine percent preferred not breach occurred. Figure 16 shows the number of
to answer. Although the percentage of respondents enterprises experiencing more or fewer breaches
who do not know may seem high, it is possible that than last year.
FIGURE 15:
In your opinion, which of the following are the most common privacy failures in an organization?
Select
In your all that apply.
opinion, which of the following are the most common privacy failures in an organization? Select all that apply.
Other 2%
FIGURE 16:
Is your organization experiencing an increase or decrease in material privacy breaches as compared to a year ago?
Is your organization experiencing an increase or decrease in material privacy breaches as compared to a year ago?
5%
16%
33% More breaches Prefer not to answer
26%
Privacy by Design
Privacy by design is a systems engineering method that Given that not practicing privacy by design is viewed as
“mandates that any system, process or infrastructure
that uses personal data consider privacy throughout its more enterprises do not always practice it. The reason
development life cycle and identify possible risk to the may be that enterprises that always practice privacy
rights and freedoms of the data subjects and minimize by design are more likely to have resources that enable
them before they can cause actual damage.”1 Figure
17 shows how often respondent enterprises practice size among enterprises that always practice privacy
privacy by design. Thirty percent of respondents
FIGURE 17: Frequency of Practicing Privacy by Design
indicate that their enterprises always practice privacy
How often
often does
doesyour
yourenterprise
enterprisepractice
practiceprivacy
by design, and 30 percent of respondents say that their
How privacy
by design?
by design?
enterprises frequently practice privacy by design.
26%
• Are more likely to separate privacy training from
30%
• Have survey respondents who are one-and-a-half times
Frequently Never
•
Sometimes
76%
Feel that their board
properly prioritizes privacy 55%
1 ISACA, “Eight Strategies to Help Organizations Implement Privacy by Design and Default,” 21 October 2021,
us/newsroom/press-releases/2021/eight-strategies-to-help-organizations-implement-privacy-by-design-and-default
by design is almost twice as large—19 compared to 10 ability to ensure data privacy and achieve compliance
for total respondents. Forty-four percent of respondent with new privacy laws and regulations. Seventy-six
enterprises that always practice privacy by design feel percent of these respondents feel completely or
that their privacy department is adequately staffed,
compared to 34 percent of total respondents. It also percent of total respondents.
appears that the boards of directors of enterprises
that always practice privacy by design better prioritize Those who always practice privacy by design are less
privacy; 76 percent of these enterprises feel that their likely to have boards that view privacy programs as
Given the various requirements privacy teams must A primary responsibility of privacy professionals is to
meet and the growing number of international privacy respond to privacy breaches. Figure 19 shows the
laws and regulations, it makes sense that the demand likelihood of experiencing a privacy breach in the
for privacy professionals is expected to grow in the next next year.
FIGURE 19:
How likely is
How likely is it
it that your organization
that your organization will
will experience
experience aa material
material privacy
privacy breach
breach next
nextyear?
year?
Very likely 4%
Likely 11%
Unlikely 20%
Conclusion
Data can provide information about an individual’s Despite the challenges associated with data privacy,
health, religion, orientation, political beliefs and more.
Protecting data subjects’ privacy is critical to building enterprise budgets have started adjusting for the growing
and preserving digital trust, so enterprises must prioritize emphasis on privacy. Privacy teams are larger this year
privacy accordingly. The number of privacy laws and than they were last year. Although there is room for
regulations will only increase in the coming years, and improvement, and many enterprises believe they need
making headlines for a privacy violation can damage more resources, enterprises are moving toward better
trust with consumers. supporting their privacy teams.
Acknowledgments
Board of Directors
Pamela Nigro, Chair Gregory Touhill
CISA, CGEIT, CRISC, CDPSE, CRMA CISM, CISSP
Vice President, Security, Medecision, USA ISACA Board Chair, 2021-2022
Director, CERT Center, Carnegie Mellon
University, USA
Former Chairman and Chief Executive
Niel Harper
CISA, CRISC, CDPSE, CISSP
Bancorp, USA
CISM, NACD-DC
USA
ISACA Board Chair, 2018-2019
Independent Director, Titus, Executive
CISA, CDPSE Chair, White Cloud Security, Managing
Senior Information Systems Auditor– Director, Clyde Consulting LLC, USA
Advisory Consulting, KPMG Uganda,
Founder, Encrypt Africa, Kenya
Israel
ISACA®
organizations in their pursuit of digital trust. For more than 50 years, ISACA 1700 E. Golf Road, Suite 400
has equipped individuals and enterprises with the knowledge, credentials, Schaumburg, IL 60173, USA
such as information security, governance, assurance, risk, privacy and quality. Support: support.isaca.org
www.instagram.com/isacanews/