Privacy Programmes for enterprise organisations.
Large organisations with multiple entities, international structures, and fragmented data face a complex challenge. One framework for the entire group? A separate approach per jurisdiction? And who keeps it all on track?
We like that challenge.








Why a privacy programme is more than a compliance exercise.
A privacy programme is the backbone for how your organisation handles personal data. For large organisations, that typically means multiple entities, varying national and international legislation, shifting roles (as controller, processor, or both) and an internal culture you want to embed consistently across the entire group.
Without a solid programme as your foundation, things go wrong quickly: requests are missed, entities follow conflicting policies, and the same work gets done twice by different teams. That inefficiency adds up, wasting time and resources across your organisation. The risks go further too. Organisations that lose track of their own data flows are more likely to face privacy violations, leading to fines, reputational damage, and a loss of trust from the people who matter most.
Why invest in a strong privacy programmes?
Complex structures demand central oversight.
Managing privacy across multiple entities means managing risk across multiple fronts. A solid programme gives you a risk-based approach: a clear, structured overview of all privacy risks across the entire group, so nothing falls through the cracks and you can act before issues escalate.
M&As and rapid growth bring new obligations.
Acquisitions, mergers and expansion into new markets move faster when your privacy house is already in order. A scalable programme simplifies due diligence, signals maturity to investors and partners, and means that when two organisations come together, there is already a shared privacy language and structure to build on.
ISO 27701 as proof of maturity.
Enterprise clients and partners increasingly expect demonstrable privacy governance. A programme built around a PIMS lays the groundwork for ISO 27701 certification and builds lasting trust with clients, partners and regulators.
Our solutions for enterprise privacy programmes.
We always start from where you are.
No programme yet? We build it together. Already have a foundation? We strengthen it with the right people and resources.
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Gap Analysis & Implementation.
No privacy programme yet, or one that needs work? We map your current situation, identify priorities, and implement a programme tailored to your group structure.
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DPO as a Service
Programme in place but no permanent DPO? Or looking to support your internal DPO with extra capacity? Our consultants take on both the Group DPO role at group level and the local DPO or privacy SPOC role per entity. We have experience in both, and integrate seamlessly into your existing structure, backed by the collective knowledge of 80 consultants across borders.
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Privacy Staffing
Privacy programme running well, but short on hands? Or do you need temporary capacity for specific tasks such as maintaining your records of processing activities, conducting DPIAs, or handling data subject requests? We help you find the right talent, whether for temporary support or a permanent role.
Why choose CRANIUM?
One point of contact. Broad expertise.
One dedicated contact person, with access to a team of 80 specialist consultants. Legal and tech under one roof.
No off-the-shelf solutions.
We work from a standardised methodology, but we know that every group structure is different. We adapt to your reality, not the other way around.
Pragmatic, not academic.
We translate complex, international legislation into what it actually means for your organisation. Concrete, actionable, and aligned with your sector.
A passion for people and data.
Privacy is all about trust. We combine technical know-how with a human-centred approach, both internally and with your teams.
International experience. Local roots.
Our consultants work across multiple languages and have hands-on experience from North America to the Middle East and Asia. We know the challenges of international organisations from the inside.
Proven quality and consistency.
Whether it's one entity or twenty, our approach delivers the same quality throughout the entire group.
What clients say about us
Meet our specialists
Marja Lubbers
Business Manager & Principal Privacy Consultant
Bart Van Buitenen
Expert Privacy Consultant
Florence Devenyi
Business Manager & Principal Privacy Consultant
Frequently asked questions
From what size or structure does an organisation need a formal privacy programme?
There is no legal threshold, but a privacy programme becomes essential as soon as your organisation processes personal data at scale, across multiple entities or jurisdictions. Without a central framework, it quickly becomes unclear who processes what, where, and on what basis. Planning growth through M&As or new markets? Then a structured programme is not a recommendation. It is a necessity.
What is the difference between GDPR compliance and a fully-fledged privacy programme?
GDPR compliance is the minimum: meeting your legal obligations. A privacy programme goes further, embedding privacy structurally into your organisation, from processes and policy to culture and governance. It is the difference between a one-off exercise and a sustainable foundation. And that is precisely where the ROI sits: organisations that embed privacy structurally avoid not only fines and incidents, but also gain efficiency, trust from data subjects, and greater agility. Compliance costs money. A strong programme earns it back.
What does a gap analysis involve in practice, and how long does the process take?
We start with a maturity assessment at group level: mapping the existing privacy structure, including roles, responsibilities, and policies. We do this using our nine building blocks for a strong privacy programme. We then zoom in on the local entities and assess their specific maturity.
The depth of that assessment depends on your needs. Sometimes a high-level analysis focused on specific GDPR elements is sufficient. Other times, we go into detailed depth per entity. At the end of the process, you receive a clear report, a concrete action plan, and an initial roadmap for your privacy programme.
The timeline varies depending on the number of entities, available schedules, and the complexity of the data flows, and typically ranges from two to six months.
Do you work with a standardised methodology, or is everything tailor-made?
Both. We start from proven frameworks, including, where relevant, the structure of ISO 27701 and PIMS. We never compromise on that foundation, as it guarantees quality and consistency. But the implementation adapts entirely to your group structure, sector, and maturity level. In practice: standardised where possible, bespoke where needed.
How do you account for different national legislations within a single group?
Through our internal Centre of Excellence, we continuously monitor the evolution of privacy legislation worldwide, from Europe to North America, the Middle East, and Asia. Our consultants are kept up to date through CRANIUM Campus and CRANIUM Academy. This means we can guide your group across borders, with knowledge that is current and applicable, wherever your entities are based.
Do you collaborate with our internal legal or compliance teams?
Absolutely. We always work as an extension of your internal teams, not alongside them. Our consultants align their approach with what already exists internally, close the gaps, and ensure knowledge transfer so that your organisation grows stronger over time, even without our support.
What if we already have a privacy programme but have doubts about its quality?
A thorough Gap Assessment is the logical first step. We independently assess what is in place, validate what works, and highlight where the programme needs strengthening, with concrete recommendations.
What is the difference between DPO as a Service and Privacy Staffing?
With DPO as a Service, we take on the statutory DPO role within your organisation, both at group level as Group DPO and locally per entity. You have a dedicated consultant, backed by the full knowledge of our team of 80 specialists.
Privacy Staffing works differently: here we help you find permanent or temporary privacy talent to work within your existing team. This does not necessarily involve taking on the formal DPO role, but it does represent a meaningful, long-term addition to your privacy function.
Do you also support ISO 27701 certification?
Yes. A sound privacy programme lays the foundation for ISO 27701 certification. We guide organisations through the preparation process and have already helped several clients achieve it successfully. The actual certification is carried out by an independent certifying body, but by the time they arrive, your organisation will be ready.
One important note: ISO 27701 builds on ISO 27001. Do not have that certificate yet? No problem. Through our sister company Cingulum, which specialises in information security, we can guide you through that process too.
Interested in our privacy solutions for large organisations?
Get in touch. Fill in the form below and we will get back to you within two working days. For urgent queries, reach us on 02 310 39 63.