Privacy Impact Assessments at Dunlap Bennett & Ludwig

OVERVIEW

Leading the way in privacy risk assessment and mitigation.

Dunlap Bennett & Ludwig (DBL) conducts Privacy Impact Assessments (PIAs) to help organizations identify, evaluate, and mitigate privacy risks before they become costly problems. Our PIAs are performed under attorney-client privilege, ensuring that all findings and recommendations remain protected while enabling a full and candid evaluation.

We guide clients who are working as agents of the federal government through compliance with U.S. and international privacy frameworks, including the Federal Privacy Act of 1974 and other unique requirements facing infrastructure providers to the federal government, such as FAR/DFARS cybersecurity clauses, FedRAMP authorization for cloud services, CMMC certification for defense contractors, NIST 800-53/171 standards for safeguarding CUI, and agency-specific mandates requiring continuous monitoring and incident reporting.

At the same time, we bring deep business acumen to PIAs conducted for commercial enterprises, ensuring that compliance with GDPR and state laws (e.g., CCPA, New York SHIELD Act, VCDPA) is tightly integrated with strategies for cost savings, operational efficiency, and revenue protection.

From mapping sensitive data flows to developing targeted mitigation strategies, we deliver clear, actionable results aligned with NIST, ISO 27001, CMMC, and other leading frameworks, helping you build trust, demonstrate accountability, and reduce legal and reputational risk.

Our experience in privacy impact assessments

Government infrastructure requires specialized privacy and cybersecurity evaluation due to embedded statutory and contractual obligations. DBL brings unique value in this space through our direct experience interpreting and implementing Privacy Act obligations for agencies and their contractors. Whether you are developing, investing in, or implementing systems that handle sensitive government data, our firm provides the strategic legal counsel needed to succeed in the evolving federal compliance landscape.

We work with clients across industries to manage the legal and business implications of privacy frameworks. Our attorneys bring a comprehensive approach, drawing from expertise in privacy law, contract law, and cybersecurity frameworks, to support businesses at every stage of privacy program development and implementation. For example, our law firm helps clients navigate privacy-related compliance challenges, including emerging laws such as state privacy regulations, federal procurement requirements, and international frameworks like GDPR. Our firm also provides strategic counsel on privacy by design implementation, vendor management, and privacy-driven business models.

Our government-facing practice combines privacy law, contract law, and cybersecurity frameworks into a single lens—enabling agencies and contractors to avoid costly missteps while meeting exacting federal procurement standards. Our corporate team assists in structuring privacy-compliant partnerships, technology transactions, and vendor relationships, ensuring privacy-related agreements align with legal best practices and risk management strategies.

DBL's Advantage: Our government clients trust DBL to interpret and operationalize agency-level mandates and procurement obligations, leveraging our experience in federal contracting and compliance frameworks. Commercial clients rely on DBL's business-minded approach to PIAs, where compliance and governance are designed not just to avoid fines but also to unlock savings, preserve revenue, and enhance enterprise value.

What we do

Provide counsel on Federal Privacy Act of 1974 & agency-specific mandates through direct experience interpreting and implementing Privacy Act obligation
Assess privacy and security requirements embedded in FAR/DFARS procurement contracts, with legal interpretation to prevent default, penalties, or disqualification
Map privacy obligations directly onto federally mandated cybersecurity frameworks including CMMC, NIST, and ISO 27001 alignment
Ensure frank evaluations of classified or restricted systems while safeguarding disclosures through attorney-client privilege in sensitive reviews
Leverage regulatory defense experience to anticipate audit triggers and design PIAs that stand up to agency audits & investigations

Evaluate business data processing against overlapping international and state frameworks including GDPR, CCPA, VCDPA & state laws
Review SaaS, cloud, and AI vendor integrations for privacy risks and cost-efficient governance in vendor & technology infrastructure
Highlight how privacy missteps can block sales, delay contracts, or result in brand damage and develop strategies to prevent revenue & market impact
Identify areas where duplicative systems, excessive vendor reliance, or inefficient consent management add unnecessary operational cost controls
Build programs that grow with business expansion without requiring repeated reinvestment through scalable privacy by design

Conduct comprehensive privacy risk assessments to identify potential regulatory concerns and compliance gaps
Map sensitive data flows across organizational processing activities with comprehensive documentation
Develop targeted mitigation strategies with specific, actionable recommendations tailored to operational environments
Ensure framework alignment with NIST, ISO 27001, CMMC, and other leading privacy and security standards

Navigate complex FAR/DFARS cybersecurity clause compliance and procurement requirements
Provide FedRAMP authorization support and guidance for cloud service providers
Offer comprehensive CMMC certification preparation and support for defense contractors
Implement NIST 800-53/171 standards compliance for safeguarding Controlled Unclassified Information (CUI)
Meet agency-specific mandates for continuous monitoring & incident reporting

Ensure coordinated approach to GDPR, CCPA, VCDPA, and emerging state privacy laws
Guide businesses in anonymization, deidentification, and ethical data usage practices
Assist in navigating global data transfer restrictions and cross-border privacy requirements
Address privacy risks associated with predictive analytics and automated decision-making

Conduct privacy assessments of third-party integrations and service providers
Structure privacy-compliant vendor agreements and data processing arrangements
Evaluate privacy risks in technology procurement and vendor negotiations
Develop vendor management frameworks that scale with business growth

Evaluate privacy risks on revenue, market access, and competitive positioning
Develop strategies that balance compliance requirements with operational efficiency
Create cost-benefit optimization approaches for privacy program implementation
Build growth-enabling privacy programs that support business expansion

Healthcare and life sciences: Privacy compliance for medical devices, patient data, and HIPAA requirements
Financial services: Privacy frameworks for consumer financial data, fraud detection, and banking regulations
Defense and aerospace: Privacy compliance in classified environments, export controls, and national security requirements
Technology and SaaS: Privacy by design for software platforms, user data protection, and global compliance
Manufacturing and supply chain: Privacy frameworks for IoT devices, operational data, and vendor ecosystems

Develop privacy governance frameworks to align with ethical and legal best practices
Create transparency and accountability frameworks for privacy compliance
Establish privacy by design methodologies for new system implementations
Design privacy impact assessment processes for ongoing organizational use

Develop privacy breach response plans and incident management procedures
Provide regulatory defense support for privacy enforcement actions and investigations
Assist in privacy-related litigation support and dispute resolution
Conduct post-incident privacy assessments and remediation planning