The technologies associated with digital tracking, as well as the related laws, regulations and risks, are complex and dynamic. This complexity requires a comprehensive governance program to adequately address the significant and growing legal and business risks that tracking technologies present. As with many aspects of data protection – but particularly with digital tracking – legal teams cannot manage the risks alone.

This third installment of a four-part article series provides a roadmap for organizations starting out– or working toward – crafting a comprehensive, cross-functional program for managing digital trackers. As discussed below, such a program requires both internal policies and processes as well as external collaboration with vendors and partners to ensure alignment in approach and adequate accountability. For many organizations, achieving sound governance over digital tracking is a daunting task. Given the complexities, for many organizations the process must be undertaken in various stages centered on risk-based decisions around prioritization.

The final part of this series will focus on digital tracker compliance challenges and solutions, including those specific to the advertising industry. Part one examined legal regulation and use risks around online tracking technologies. Part two took a deep dive into the technical workings and types of digital data collection tools.