Creating or further developing a privacy program is no simple task, and successful and sustainable privacy programs are built on multiple foundational elements. In this second part of our series on building an efficient global privacy program, we discuss those foundational elements, the gap analysis and how to create an adaptable program with insights from lead privacy officers at VMWare, Zillow, Yahoo, Toyota Financial Services, Johnson Controls and T-Mobile. Part one addressed organizational structure, including where privacy sits, roles and responsibilities of the team, common reporting structures and coordination with other business units. Subsequent installments will address implementation approaches, including use of frameworks and automation tools, and assessing, maintaining and updating the program. See “Eleven Key Components of an Effective Privacy Program” (Feb. 26, 2020).