Organizations continue to face an expanding and increasingly complex privacy landscape. With many states now enforcing comprehensive privacy laws, federal privacy laws focused on specific areas and industries, continued global regulatory activity, and growing expectations around AI governance, 2026 is a pivotal year for strengthening privacy programs. At this ACC Central Florida CLE session, we outlined six practical resolutions to help organizations proactively manage privacy risk and operationalize compliance.
Resolution 1. Understand Which Privacy Laws Apply
Privacy obligations vary based on business operations, customer and employee locations, industry sector, and profit status. Federal laws such as GLBA, HIPAA, COPPA, and FERPA may preempt state laws in certain contexts. Nonprofits are exempt in some states but not others. A clear applicability analysis is the foundation of any compliance strategy.
Resolution 2. Review Public‑Facing Privacy Notices
Organizations should verify that online privacy notices, delivered/mailed notices, cookie policies, and terms of use are accurate, current, and aligned with actual practices. Many notices remain outdated, overly California‑centric, or inconsistent with internal operations. Regular review reduces regulatory and litigation risk.
Resolution 3. Create Workflows to Implement Your Notices
Privacy notices create obligations. Organizations must be prepared to intake, verify, evaluate, and respond to consumer or data subject requests, often within 45 days. Internal retention and disposition policies must match what is stated publicly. A documented “playbook” is an effective tool to create consistent, timely, and defensible responses.
Resolution 4. Conduct Assessments to Understand Data and Risk
Many assessments are not just best practices, they are legal requirements under laws such as the GDPR and numerous U.S. state privacy statutes. Organizations use these assessments to understand where personal data resides, how it is used, and what risks may arise. Core activities include mapping data flows, evaluating the necessity and impact of processing, identifying higher‑risk practices such as sensitive data use or targeted advertising, and reviewing AI systems for transparency, fairness, and lawful data use. These assessments strengthen visibility, support compliance obligations, and enable informed, risk‑based decision‑making.
Resolution 5. Consider Tools to Support Compliance
Technology helps streamline privacy operations by improving data discovery, identifying tracking technologies, managing consent, and supporting vendor oversight. The right tools depend on an organization’s size, risk profile, data environment, and overall maturity. Identify use cases where automation enhances efficiency and reduces compliance risk and aligns with budgetary constraints.
Resolution 6. Review Third‑Party Vendor Agreements
Making privacy a standard part of contract review and vendor oversight is a good practice that helps create consistent protection of personal information throughout the relationship. Contracts can outline how data is shared, the purposes for which it may be used, required security measures, retention and disposal expectations, and any cross‑border transfer mechanisms. This includes agreements governing data sharing, joint marketing activities, and international transfers.
Conclusion
These six resolutions offer a practical roadmap for strengthening privacy governance in 2026. By understanding applicable laws, maintaining accurate public disclosures, operationalizing workflows, conducting meaningful assessments, leveraging appropriate tools, and managing vendor risk, organizations can build a resilient and forward‑looking privacy compliance strategy.
Contact Information
Tom Corey
tcorey@gunster.com
(980) 322-4679
Cricket Wood
cwood@gunster.com
(727) 354-9533
YES! PLEASE SIGN ME UP TO RECEIVE EMAIL ALERTS FROM OTHER GUNSTER PRACTICE AREAS.
This publication is for general information only. It is not legal advice, and legal counsel should be contacted before any action is taken that might be influenced by this publication.
Gunster. Florida's Law Firm for Leaders.
As a full-service law firm, Gunster provides full-service legal counsel to leading organizations and individuals from its 13 offices statewide. Established in 1925, the firm has expanded, diversified and evolved, but always with a singular focus: Florida and its clients’ stake in it. A magnet for business-savvy attorneys who embrace collaboration for the greatest advantage of clients, Gunster’s growth has not been at the expense of personalized service but because of it. The firm serves clients from its offices in Boca Raton, Coral Gables, Fort Lauderdale, Jacksonville, Miami, Naples, Orlando, Palm Beach, Stuart, Tallahassee, Tampa, Vero Beach, and its headquarters in West Palm Beach. With more than 320 attorneys and consultants, and 300 committed support staff, Gunster is ranked among the top 200 largest law firms by the National Law Journal and has been recognized as one of the Top 100 Diverse Law Firms by Law360. More information about its practices, industries, offices and news is available at www.gunster.com.
