​Cultivate a Privacy-First Mindset

Summary: Privacy is a must for AI products, and TPMs are the key drivers in ensuring user data is safeguarded and trust is maintained.

• The challenge is real: TPMs must navigate the delicate balance between innovation and privacy concerns in fast-moving development environments.

• How can TPMs tackle this? There are strategies to instill a privacy-first mindset from the start—strategies that go beyond just compliance and into the realm of proactive protection.

In the fast-paced world of tech, where innovation drives the creation of cutting-edge products, Technical Program Managers (TPMs) have an essential role in ensuring that those products are delivered on time, at scale, and with the highest quality. Part of that mission goes beyond engineering efficiency and product delivery. It’s about proactively identifying gaps that can turn into risks, or worse, costly mistakes—especially when it comes to privacy.

With the rise of Gen AI powered products, a Privacy-First Mindset has never been more important. TPMs need to take the lead, not only in building high-quality solutions but in embedding privacy practices into the DNA of the development process. Here’s how TPMs can contribute to creating a privacy-conscious, secure, and user-centric product from the start.

What is a Privacy-First Mindset?

In simple terms, a Privacy-First mindset means building privacy protections and practices into the design from the very beginning, rather than scrambling to respond when a privacy incident occurs. It’s about anticipating privacy needs and proactively making engineering and product decisions that protect the users’ personal data and their activity on your platform. In today’s environment, where personal data is incredibly valuable and vulnerable, being proactive in safeguarding privacy isn’t just a good practice—it’s a must.

How TPMs Can Help Implement a Privacy-First Mindset

TPMs are uniquely positioned to help instill and evangelize privacy-first thinking across the organization. Here’s how you can lead the charge:

1. Involve Privacy and Legal Stakeholders From The Start – Privacy isn’t something to think about at the last minute—especially in industries with stringent regulations like GDPR (EU Data Privacy Legislation) or CCPA (California Consumer Protection Act). Involve your privacy and legal teams early in the planning and tech design process. This ensures privacy considerations are baked into every decision, and that legal and regulatory requirements are met before they become bottlenecks.

2. Be Deliberate About Privacy Milestones – Integrate clear privacy milestones into your project schedule. This ensures privacy is reviewed and prioritized at every stage, making it an ongoing process, not a last-minute check.

3. Privacy by Default – Encourage the principle of “privacy by default.” This means that users should be able to use your product with maximum privacy protections without needing to take extra steps. This should apply to everything from user data handling to opting in or out of data sharing, ensuring that privacy isn’t an afterthought.

4. Make Privacy Review a Gating Sign-Off Before Launch – Set privacy reviews as a gating factor in your launch process. If the product or feature doesn’t meet privacy standards, it doesn’t move forward. Think of it as a “non-negotiable” checkpoint that ensures compliance and user trust, rather than just a nice-to-have task.

5. Don’t Treat Privacy Issues as P2 (Nice to Have) – Privacy should never be treated as a secondary concern. It’s not just a checkbox. If privacy concerns arise, treat them as high-priority issues (P1), addressing them swiftly rather than putting them off or delegating them to a later sprint or release.

6. Take Extra Care with User Data or PII – Be extra vigilant when working with user data or Personally Identifiable Information (PII). Ensure that all data is stored securely, anonymized where necessary, and that access is granted only on a need-to-know basis. TPMs can help facilitate discussions about security architecture and data protection from the start.

7. Integrate Privacy-Focused QA Testing – Make privacy-focused quality assurance testing an integral part of your development cycle. This ensures that privacy issues are identified before release and that solutions are thoroughly vetted for data protection throughout the entire development process.

8. Avoid Dark Patterns in Your Design – Dark patterns are design choices that manipulate users into actions they may not want to take, such as unknowingly opting into data sharing. As a TPM, you should work closely with your UX/UI and product teams to ensure ethical design practices, creating transparent, user-friendly interfaces that empower users to make informed decisions about their privacy.

9. Evangelize and Support Cross-Functional Teams in a Privacy-First World – Encourage marketing, sales, and other cross-functional teams to also adopt privacy-first practices. This could mean changing the way marketing communicates about data usage, access to user data for marketing and sales campaigns or ensuring that legal disclaimers are clear and accessible. Every team must align with privacy standards to deliver a consistent, trust-building user experience. This will be the hardest thing for you to as it requires a massive culture shift at your organization.

Inside Google

At Google, with every launch of Android Things, I had to complete a detailed Privacy and Security intake form as part of the LaunchCal checklist. This form covered everything from the types of user data being used, the age range of users, to whether we were dealing with sensitive PII. After submitting the form, it was reviewed by the Privacy Counsel team, and additional follow-ups were required. As a TPM, it was my responsibility to gather all the necessary technical and operational information and ensure Privacy Counsel provided the necessary sign-off before the launch Go/No Go meeting with senior leadership.

Inside Apple

At Apple, each cross-functional team had a dedicated Privacy Engineer DRI who was responsible for ensuring that every design and architectural decision prioritized privacy from the outset. These Privacy Engineers were highly knowledgeable in common attack vectors, privacy issues, and privacy law compliance, with a solid engineering background that made them more than just interpreters—they were active contributors to the technical team. As an EPM, I found these Privacy Engineers to be invaluable partners in helping instill a privacy-first mindset throughout project development.

Inside Nike

The most surprising aspect of building a modern data privacy platform at Nike was the numerous marketing teams constant concern about losing access to valuable user data for their multimillion-dollar campaigns. For years, marketing teams had grown accustomed to unrestricted access to a wide range of user data repositories. The prevailing culture was to collect as much data as possible upfront, then develop hypotheses and analyze later. However, the Chief Privacy Officer and VP of Privacy Legal worked diligently to shift this mindset—emphasizing the importance of defining the right questions first and collecting only the necessary data. This cultural shift is arguably one of the biggest challenges when building a privacy-first framework.

Instilling Privacy Mindset Today

If you want to start building a privacy-first mindset immediately as a TPM, one of the most impactful things you can do is make Privacy Review a gating sign-off for your next launch or release.

Begin by reviewing your architectural diagrams, assessing how user data is being used, and ensuring you are properly protecting PII; consult with Outside Counsel if in-house Privacy Counsel support doesn’t exist to ensure you are complying with up to date privacy regulations.

It’s also important to verify that you have the right rollback mechanisms in place in case something goes wrong after launch. This is within your control as a TPM, so take action and start driving privacy-first practices tomorrow.

Final Words

In the rapidly evolving world of technology, where new privacy challenges seem to emerge every day, TPMs have the power to make a huge impact. By adopting a Privacy-First mindset and leading by example, you not only protect your users but also build products that inspire trust and confidence.

Start embedding these principles today, and you’ll not only safeguard privacy but position your product for long-term success. After all, privacy isn’t just about compliance—it’s about valuing the trust users place in your brand and the responsibility you hold in safeguarding it.

Until next time!

-Aadil