When Should You Bring in Outside Support for Your Privacy Program? 

When in need of support, most privacy leaders are not looking for someone to come in and take over their program, they’re looking for assistance and an outside perspective. They’re looking for clarity — on where the gaps are, what to prioritise, and whether what they have built is working the way they think it is, from people who have seen it before.  

The question of when to bring in outside perspective is one that comes up consistently in conversations about privacy program development. And it is a more nuanced question than it might appear. Inside knowledge matters. So does the view from outside the building.  

In a previous Myna Partners webinar, Dave Cohen and Aaron Weller discussed the moments when internal teams reach a ceiling — and what typically prompts the decision to bring in external support. 

Why Is It Hard to Know What “Good Looks Like”From Inside Your Own Program? 

Aaron made a point during the session that is worth reflecting on: It’s very hard to know what good looks like if you haven’t seen it anywhere else. Teams that have only ever operated within one program, one organisation, one way of doing things, often do not have a clear reference point for whether what they have is genuinely effective or just familiar. 

“If you don’t know what good looks like, it’s really hard to get there if you have no idea what you’re driving towards.” — Aaron Weller, Leader of Privacy Innovation and Assurance, HP 

This is not a criticism of internal teams. It is a structural reality. Deep institutional knowledge is genuinely valuable — knowing the organisation’s history, its relationships, its risk tolerance, its culture. But that same depth can make it difficult to see the program clearly and create a myopic lens. When you are inside something, you adapt to its quirks. An outside perspective surfaces what has become invisible through familiarity.  

What Is the Minimum Viable Compliance Moment and Why Does It Matter? 

One signal that external perspective might be useful is what Dave described in the webinar as the minimum viable compliance moment, the point where the program has done enough to seemingly meet immediate requirements, but stops there.  

Dave used the term MVC (minimum viable compliance), not as a ceiling to aim for, but as a checkpoint. The program gets to a place where it can reasonably withstand regulatory scrutiny. And then the question becomes: what next? Where are the prioritisation decisions? What should the program tackle next to move from adequate to genuinely effective? How do you build deep resilience in the program?  

That is a moment where an outside view adds real value, not because internal teams can’t answer those questions, but because having a team who has seen many programs across multiple organisations in various sectors examining the fact patterns often produces a clearer picture than an internal team can generate from within.  

When Does Over-Dependence on a Few People Become a Risk? 

Another consistent signal is when the program’s operational continuity depends heavily on one or two people who hold most of the institutional knowledge. Aaron raised this directly in the session and not as a failure, but as a risk that most programs underestimate. This is a common side effect of companies “running lean”.  

The practical consequences become visible when those people leave, change roles, or are simply unavailable. Processes that were never written down stop happening. Relationships that were maintained informally go cold. Decisions that one person always made become unclear.  

External support in these moments serves two purposes. It brings continuity during transitions. And it is an opportunity to document and formalise what was previously held in people’s heads, building the kind of institutional memory that does not walk out the door with any one person.  

How Do You Know When the Program Is Growing Faster Than Internal Capacity? 

Privacy functions and programs, many of which are now quite mature, are being asked to take on additional responsibilities. AI governance is increasingly landing in the privacy function. Third-party risk management is expanding. Regulatory requirements across jurisdictions are multiplying. The scope of what a privacy team is expected to manage has grown significantly over the last two decades, and in most organisations, the headcount has not kept pace.  

This is not a situation where the team is doing something wrong. It’s a situation where the work has outpaced resources. And it’s one where bringing in specialist depth, on a specific project, a specific regulatory requirement, or a specific capability area and can be more practical than trying to build that depth internally from scratch.  

The question is not whether to build internal capability over time. It’s whether the program can afford to wait while that capability develops, or whether there is a faster path to getting the work done well.  

What Do Internal Teams Do Best and When Should They Stay in Charge? 

None of this is an argument against internal teams. The things that internal teams do best are real and difficult to replicate from outside: understanding the organisation’s culture, navigating its politics, maintaining the relationships that make compliance work happen, and building the kind of sustained momentum that only comes from people who are genuinely invested in the long-term health of the program.  

The most effective arrangements tend to combine both. Internal ownership of the program’s direction, relationships, and continuity. External support for specific assessments, capability gaps, or moments where a fresh perspective is more valuable than familiarity.  

As Dave noted in the session, the goal is not to hand the program over. It is to use outside perspective to see the program clearly and then to build from that clarity.  

Frequently Asked Questions

When should a privacy team bring in outside support?

Four signals consistently point to the right moment: when the team only sees what it is used to seeing, when the program has reached minimum viable compliance and does not know what to build next, when continuity depends on one or two people, and when the scope of work has grown faster than internal headcount.

What is minimum viable compliance in a privacy program?

Minimum viable compliance is the point where a program has done enough to meet an immediate regulatory requirement but has not yet built the depth or structure to go further. It is a checkpoint, not a ceiling. Reaching it is progress, but it is also the moment to ask what comes next and whether the foundation is solid enough to build on.

What are the risks of overreliance on key individuals in a privacy program?

When operational continuity depends on one or two people, the program’s institutional knowledge walks out the door if they leave or change roles. Processes that were never documented stop happening, relationships go cold, and decisions become unclear. External support during transitions can bring continuity and create an opportunity to formalize what was previously held in people’s heads.

What do internal privacy teams do that outside support cannot replicate?

Internal teams bring deep institutional knowledge, the organization’s history, its relationships, its risk tolerance, its culture. That understanding of how to navigate the politics and maintain the relationships that make compliance work happen is difficult to replicate from outside. The most effective arrangements combine internal ownership of the program’s direction with targeted external support for specific gaps.

How do you know if your privacy program needs an external assessment?

A useful question to ask is whether the team has a clear reference point for what a genuinely effective program looks like. Teams that have only operated within one organization often adapt to its quirks without realizing it. If there is no external benchmark, it is very hard to know whether what exists is effective or just familiar and that is when an outside view adds the most value.

>> Start from the beginning: The Remediation Gap: What Privacy Program Health Checks Consistently Reveal