October 24, 2025 · 5 min read
The Data Privacy Conversation Every Client Needs, Even if They Don't Ask
Most clients don't bring up privacy until a regulator or a journalist does. Raising it unprompted, early, has saved more than one project from a much worse version of that conversation later.
I was hired once for a straightforward tagging implementation, nothing privacy-related in the scope. Two days in, I noticed the client was passing full, unhashed email addresses into a third-party pixel that had nothing to do with the scoped work and everything to do with a data-sharing agreement nobody on the marketing team seemed aware existed.
It wasn't in my contract to flag it. I flagged it anyway, in a short, specific message — not alarmist, just factual about what data was leaving and where. The client had no idea it was happening; it turned out to be leftover from an integration set up two years earlier by someone no longer there.
A client who finds out about a privacy exposure from a regulator trusts you less than one who finds out from you, even if it's not technically your job to tell them.
Why I raise this unprompted now, every time
Most clients genuinely don't know what's leaving their stack. They hired someone to build a feature, not to audit privacy exposure, so nobody's specifically looking for it unless it's someone's actual job — and in most mid-size companies, it isn't clearly anyone's job. A consultant who's already in the tracking layer is often the only person who will ever see it before it becomes a real problem.
- I now scan for unhashed PII in outbound requests as a standard, unbilled five-minute check on any project touching tracking, regardless of scope.
- I flag anything found immediately and in writing, with no judgment attached — this is almost never anyone's current fault.
- I don't try to fix it under the existing scope unprompted; I raise it and let the client decide whether to scope a fix.
- I document that I raised it and when, which protects both of us if it becomes a larger issue later.
This costs me a small amount of unbilled time on every project. It's bought more trust and more follow-on work than almost anything else I do, because it demonstrates something a client can't easily verify about a consultant any other way — that I'm looking out for their risk even when it's not explicitly what they're paying me for.