We were just two minutes into a call when a privacy leader jumped in with:
“We’d like to start with code scanning. You can do that for us first, right?”
Me: “We could. Just curious…have you tested your consent banner recently?”
Leader: “Not really. Why?”
Me: “I took a quick look before our call. It’s not blocking all trackers after opt-out.”
Leader: “Oh… I didn’t realize that.”
Me: “Mind if I be direct for a second?”
Leader: “Sure.”
Me: “Consumers and regulators will visit your website first. We advise folks to start there, before doing anything else.”
Leader: “But isn’t code scanning more advanced?”
Me: “Consumers and regulators are not inspecting your code. They’re looking at your website.
Me: And right now, your opt-out is not working. That’s what they’ll notice first.”
Leader: “Fair. I guess we’ve been thinking more about internal system risk.”
Me: “Makes sense, we hear that quite a lot. But if your website is not compliant, the internal code in your database is simply less important. And this isn’t hypothetical. Someone came up to us at IAPP last week asking about code scanning… while their consent banner was actively failing live.”
This wasn’t a theoretical exchange—it was a real conversation with a real privacy leader. And it wasn’t an isolated incident.
Just recently at IAPP, someone came to the DataGrail booth and asked about code scanning for their privacy program… while their consent banner was actively failing live on their website.
Here’s what we’ve learned after working with hundreds of privacy, legal, and security teams:
- Start where risk is visible. Consumers and regulators will judge your program by what they can see and interact with.
- Start where users interact. Your website is the front line—it’s where people experience your brand and your commitment to privacy.
- Start with rights, including consent. If you’re not honoring opt-outs, it doesn’t matter how well your internal processes are managed.
That doesn’t mean internal code risk or shadow IT doesn’t matter—they absolutely do. But they come after you’ve laid the foundation of visible, user-facing privacy controls.
When your website is compliant, when your consent banner actually works, and consumer rights are respected by default—that’s when you’re ready to go deeper. That’s when you build on your foundation to scan for risk across internal systems, code, SaaS tools, and more.
Need help evaluating where to start?
Book a demo with our team. We’ll walk you through where your current privacy setup might be falling short—and how to solve it, starting with what matters most.
