Engineering Trust: The New Operating Model for Data Privacy

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Ramakanta Mohapatra
Vice President & Head - Data Protection & Governance

 

Introduction: Privacy no longer is ‘legal’; it’s an ‘operational’ model 

Data has become the most overused word in boardrooms and the most under-managed reality in operations. In financial services, data is no longer just an asset. It is a liability the moment it is left ungoverned, copied into the wrong workflow, shared without clarity, or retained longer than it should be. And 2026 is going to be different for one simple reason: the margin for improvisation has collapsed. 

Innovation is accelerating. AI-driven models are reshaping how banks, NBFCs, insurers, and fintechs operate. Customer journeys are getting faster, more embedded, and more cross-border by design. At the same time, privacy regulation is expanding, enforcement is tightening, and expectations around transparency are rising. 

The 2026 privacy reality: overlapping laws, shrinking tolerance 

Most privacy conversations still start in the wrong place, with a single regulation. That is not how the real world works anymore. 

Financial institutions today operate inside a stacked compliance environment: privacy laws, sectoral mandates, cross-border transfer expectations, and contractual obligations with partners, processors, and vendors. These requirements overlap and converge on one shared outcome: protect personal data, respect individual rights, and demonstrate accountability. 

If you operate across regions, you are likely navigating a mix of frameworks such as: 

  • The Middle East’s Personal Data Protection Laws (PDPL variants across countries) 
  • Southeast Asia’s Personal Data Protection Acts (PDPA variants) 
  • Plus financial regulators and industry mandates that shape what “secure” and “responsible” processing looks like in practice 

This is why in data privacy, partial compliance is not a strategy. It is exposure. The real risk is not that you do not have policies. It is that you cannot demonstrate execution. 

Why the “globalization of privacy” changes everything 

Here is the shift most teams underestimate: privacy is no longer regional. While a significant portion of countries have enacted data protection laws, the impact is not simply “more rules.” It is a structural change in how business gets done. Because the modern financial ecosystem is inherently cross-border with multi-country product rollouts, shared service centers, offshore processing partners and global fraud, risk, and support workflows, this creates a problem. If you operate in multiple jurisdictions, you cannot build 12 different privacy programs and hope they stay aligned. What organizations must instead do is design their privacy posture around the highest common denominator of controls, then localize where a jurisdiction requires something specific. The strategic priority is to embed data privacy into the business DNA, so controls survive change. That is why privacy by design matters. Not as a slogan, but as an operating principle, and this where data privacy consulting services can help organizations operationalize it.  

The trends shaping privacy programs in 2026 and beyond 

If 2025 was the year data privacy became urgent, 2026 is the year privacy becomes engineered. What will separate mature programs from reactive ones is not intent. 
It is structure. Here are the pillars that will define data privacy programs in 2026 and beyond: 

Privacy culture, training, and accountability

Privacy fails most often through people and process, not through policy. The institutions that improve posture will invest in training that is role-based, repeatable, and tied to accountability, not annual box-ticking. 

Consent and purpose-based controls

Consent is not a banner on a website. It is an operational system that must handle the full data lifecycle: collection, withdrawal, updates, and proof. Purpose limitation becomes real only when your controls enforce it. 

Third-party risk becomes the frontline

The world is moving toward outsourced processing at scale: cloud providers, fintech partners, KYC vendors, analytics platforms, customer engagement tools. Your risk posture is only as strong as your weakest processor. 

Data subject rights move from “policy” to “operations”

Rights are not theoretical in 2026. Customers expect access, correction, deletion, and grievance handling within defined timelines. Your ability to deliver this consistently becomes a trust signal. 

Privacy-preserving technologies become practical, not optional

Encryption, masking, tokenization, access controls, and monitoring are not “security features.” They are privacy enablers, especially in environments where data is reused across teams and workflows. 

Threat detection and response must assume breach

Zero breach is not a plan. Resilience is. Organizations will need forensic readiness models that include breach response workflows, evidence management, and regulator communication playbooks. 

Responsible AI governance becomes unavoidable

As AI use expands, privacy teams are now forced to answer new questions: 

  • What data did the model learn from? 
  • Who approved the dataset? 
  • Can we explain the outcome? 

Responsible AI is quickly becoming a privacy and trust requirement, not an R&D concern. 

Cross-border data movement becomes a governance discipline

Cross-border is no longer “legal reviewed the contract.” It is transaction-level gatekeeping: who shares what, where, why, under what controls, and how you prove it. 

Conclusion 

Data privacy is no longer a “compliance requirement” you handle after the product ships. It is the operating discipline that decides whether you can scale with confidence. If you get this right, compliance becomes more than risk reduction. It becomes a competitive edge. But moving from intent to execution demands a structured approach to data discovery and classification, governance, controls, and evidence, grounded in both regulatory understanding and operational realities. This is where specialized data privacy consulting services and implementation frameworks can help organizations translate regulatory expectations into executable controls. The organizations that win in 2026 will not be the ones claiming they respect privacy. They will be the ones proving it, consistently, across every workflow that touches data. 

 

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