The Seven Keys to Privacy in 2025: Confidence Rebounds, AI Disrupts, and Leaders Double Down

When TrustArc first published the Seven Global Keys to Privacy, the goal was simple: identify what separates high-performing privacy programs from the rest. This is more important than ever in a landscape now reshaped by artificial intelligence, regulatory expansion, and surging public expectations. The foundational keys remain the same, but the stakes are higher, and the gaps between leaders and laggards have widened.

A comeback in the Global Privacy Index

For the past six years, our annual global survey gathered multiple ratings on privacy in day-to-day operations, leadership, organizational approaches, and confidence among stakeholders. We obtained 360° input from all levels within medium and large-sized organizations. We then narrowed all of the questions we asked into a subset that statistically best correlates with stakeholder confidence in their organization’s approach to privacy. Below, we report on the Global Privacy Index, the grand mean of these measures.

After a drop to 50% in 2022, the 2025 Global Privacy Index rebounded to 61%, regaining lost ground. This recovery reflects real progress, but polarization is still evident. In 2025:

• 39% of companies achieved exceptional scores of 75%+, up six points from the initial starting point of the Index.
• 37% got passing scores of 50%–74%.
• 24%, almost a quarter, had failing scores of under 50%.

What drives improvement? A clear privacy blueprint: centralized teams, purpose-built privacy tools, measurable KPIs, principle-based approaches to regulation, and the strategic integration of privacy into operations.

The 7 keys to privacy: Enduring and evolving in 2025

The 2025 TrustArc Benchmarks Report reaffirms the original seven core competencies of privacy excellence with the latest findings:

1. Strategic integration

78% of organizations now consider privacy a core part of business strategy, embedding it into decision-making processes, up from 2022 levels.

2. Privacy mindfulness

82% of respondents reported that their company is mindful of privacy as a business.

3. Employee empowerment

77% agreed that any employee can raise a privacy concern without fear of reprisal, reinforcing a culture of accountability and psychological safety.

4. Board-Level engagement

74% of organizations said their Board regularly reviews privacy issues, a sign that governance structures are catching up with reputational and regulatory risk.

5. Training and awareness

71% report broad training across roles. Programs have expanded beyond compliance to emphasize risk awareness and evolving threats like AI misuse.

6. Privacy as a differentiator

69% of firms agree that privacy is now a competitive differentiator.

7. Operational mindfulness

88% of companies say privacy is considered in many or most business decisions, showing deep operational integration of privacy into day-to-day workflows.

Five outcomes that matter: Culture and confidence

The most promising shift? Stakeholder confidence is on the rise:

• 47% now have complete confidence in how their organization protects employee and customer data, up 19 points YoY.

Along with confidence in privacy management rising year over year, stakeholder groups also showed gains. Complete confidence in privacy management is highest among employees (30%), followed by customers (29%), partners and third parties (28%), and the general public (25%). The latter of which reflects lagging concerns around reputational risks.

This confidence is not built through policy alone. It’s built by leaders who embed privacy into strategy, give teams the tools to succeed, measure what matters, and act before regulations compel them to do so.

Purpose-built and measurement: The great dividers

Software matters. Companies using commercial, off-the-shelf privacy management software achieved the highest Privacy Index scores (71%), 10 points above the Grand Mean. By contrast, firms using free or open source tools averaged seven points below average, at 54%.

Adoption of purpose-built platforms remains limited. Only 20% have fully implemented such systems. However, those who have already purchased and fully implemented a commercially available Trust Center scored 78% on the Privacy Index.

KPIs draw the line between success and failure

In 2025, measurement remains a powerful predictor of privacy success:

• The 82% of medium and large firms that measured their privacy programs and implemented KPIs scored 74% on the Privacy Index, thirteen points above the Global Grand Mean.
• Those who did not implement KPIs averaged just 29%, a low failing grade, 32 points below the average.

Measurement is no longer optional. It is the line between success and failure. Organizations that track privacy effectiveness with privacy-specific KPIs are not just more accountable; they perform better by a full 45-point margin over those who do not put anything in place.

These findings make measurement one of the strongest single predictors of privacy competence in 2025. Privacy has entered the KPI mainstream. Methodical assessment creates organizational clarity and drives action.

Completed internal assessments remain the most common KPI, along with the number of privacy-related customer inquiries/complaints resolved and PIA completion rates.

In terms of a company’s primary methods for measuring their privacy program, the three most popular were audit assessments, time to complete data subject access requests (DSARs), and implementation and compliance with several privacy laws. Leaders do not just measure outputs; they monitor the health of their privacy pipelines.

Implementation gaps persist, but maturity pays off

While intent is widespread, execution remains shallow. Fewer than four in ten companies (36%) have implemented even three core privacy initiatives to full maturity. These capabilities include:

• Cookie consent.
• Data subject rights requests management.
• Breach notification processes to regulators and our clients.
• Privacy assessment processes throughout our supply chain (e.g., PIAs or vendor assessments).
• Strategic and reportable privacy program management.
• Having third party privacy certifications (for example, EDAA Certification, APEC CBPR & PRP Certification, Data Privacy Framework).
• Having other certifications (for example, ISO 27001, ISO 27701, SOC2).
• Maintaining or building a Trust Center (public or consumer facing portal for privacy/security/legal).
• Data discovery (automated scanning to identify, classify, and analyze personal and sensitive data).
• Data inventory and mapping (build a data inventory and ROPA to mitigate compliance for privacy compliance and audits).

Yet those who have fully implemented all of these privacy capabilities reaped the rewards, with Privacy Index scores that leap 21 points above the global average, at 82%. The gap is no longer in awareness of what to do; it is in operational follow-through.

Trust talk is cheap. While 88% of firms say brand trust drives their privacy investments, only a quarter back it up with a comprehensive privacy platform.

Frameworks and regulatory approaches: Stability in a storm

While privacy laws and technologies evolve rapidly, certification frameworks offer stability and strategic value. TrustArc’s 2025 benchmarks show that organizations aligning with globally recognized standards score significantly above average in privacy competence.

Among them, the Nymity Privacy Management Accountability Framework (PMAF) stands out. Designed to embed accountability into privacy operations, Nymity PMAF users reported Privacy Index scores of 75%, a full 14 points above the global mean.

Other high-impact certifications include AICPA/CICA, COBIT, and APEC CBPR. These frameworks do more than demonstrate compliance; they operationalize privacy governance. By codifying roles, responsibilities, and reporting structures, they help turn privacy from a reactive function into a source of strategic value.

Additionally, the 22% of organizations that have adopted a principles-based regulatory approach outperform others by a wide margin, scoring 73% on the Privacy Index versus a 56% average Index score among the 31% taking a rules-based approach.

In stark contrast, those lacking any defined regulatory approach, which fortunately is quite small at just 5% of companies, score dismally at 13% on the Index. These findings underscore the performance gaps among strategic, reactive, and non-existent compliance models.

The AI disruption: A new dimension to privacy competence

AI is the #1 privacy challenge. In 2025:

• 46% of privacy professionals rated AI privacy risks as extremely challenging
• Only 29% are very prepared for new laws like the EU AI Act, and 26% for the Colorado AI Act. Those who are prepared scored above average on the Privacy Index, at 65% and 66%, respectively. Those who are very prepared achieved top marks, averaging 80% and 82%, respectively.

Companies that have embraced AI in their technology stack are also leaders in privacy management. The two go hand-in-hand.

The data shows clearly: those with “strong alignment with a common understanding and approach across roles” as well as those where the privacy and AI teams are well coordinated with clear processes, score 77% on the Privacy Index, 16 points above the global average. Their privacy practices are distinguished by:

• Robust data mapping and inventory.
• Use of third-party certifications.
• Strong data subject rights request systems.
• Centralized privacy structures.

If you’re ready to benchmark your own program against top performers and dive deeper into what AI readiness really looks like, explore why forward-thinking privacy pros are outpacing the pack in our companion article on AI compliance.

From compliance to leadership

The 2025 TrustArc Benchmarks show a world of progress, and increasing benefits and challenges brought on by AI. While the privacy elite are racing ahead with structured programs, AI preparedness, and measurable outcomes, many others are falling behind.

The Seven Keys to Privacy are not a static checklist. They are a lens through which privacy leadership is defined, measured, and earned. And in 2025, leadership is not optional; it is existential for privacy leaders.