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A hallmark of successful scale-ups is rapid growth – more users, more data, more features, and expansion into new territories. However, as a health tech organisation grows, keeping track of data flows and maintaining transparency becomes exponentially harder. Startups often operate in “build fast” mode, which can lead to ad-hoc data practices that don’t scale well under regulatory scrutiny.
When you have ten employees and a few hundred users, it’s feasible to know where all personal data is stored and who has access to what. But once you’ve grown to tens of thousands of users and integrate with numerous third-party services... do you still have an accurate map of what data you collect, where it’s stored, and how it moves through your systems? Many organisations discover at this point that they do not. This lack of visibility is risky. If you don’t know your own data flows, you can’t be transparent to users or regulators about them.
A common issue is insufficient internal expertise and training. Health tech firms often lack dedicated privacy officers or IT security staff in the early stages of their growth. As a result, employees may unwittingly introduce vulnerabilities – e.g. using unsecured devices for work, mishandling sensitive emails, setting weak passwords, or falling for phishing scams. (In the UK, an astonishing 90% of businesses identified phishing attacks as the most common cyber threat they faced. Human error remains one of the top causes of data breaches globally[45] - far more prevalent and damaging that more technically-led cyber attacks. Scaling up without raising privacy and security awareness internally is a recipe for incidents.
Moreover, once you operate in multiple jurisdictions, incident response obligations become a complex web. If a breach occurs, you may need to notify different regulators (and possibly impacted individuals) on different timelines with different content requirements. For instance, under GDPR you have 72 hours to notify the Data Protection Authority; under Australia’s regime, you must notify individuals “as soon as practicable” if a breach likely causes serious harm; under some US. state laws, you notify the state attorney general for large incidents affecting residents. This puts pressure on organisations to have robust breach detection and response systems. You can’t afford to discover a breach a month after it has happened – by then, you might already be in violation of a 72-hour rule.
When these challenges (poor data mapping, low staff awareness, multi-jurisdiction incident rules) are not addressed, the consequences include operational delays and compliance failures. If you’re unclear on what data is collected and where, it becomes extremely hard to respond to a data breach or a user’s request. We’ve seen companies scramble during an incident, asking basic questions: “Which database was that data in? Was it encrypted? Who do we need to inform?” Such delays can mean missing notification deadlines, which can lead regulators to levy additional fines or take stricter action. Not to mention, a disorganised breach response undermines user trust – customers perceive (rightly) that the company doesn’t have its act together in protecting their data.
To maintain accountability at scale, processes and documentation are key. Implement a regular data mapping exercise: update internal business processes (usually held, for anything connected with personal data, in a dedicated record of processing activities or RoPA) whenever you launch a new feature or onboard a new vendor . Build a culture of transparency – some companies, for example, have internal “data champions” in each of their teams who ensure new projects a through a privacy review or DPIA and that privacy notices are updated. Conduct periodic privacy training for all employees (and more advanced training for engineers, product managers, and customer support who regularly deal with sensitive data). Importantly, have an Incident Response Plan that is tailored to privacy/security incidents. This plan should include: how to escalate a potential breach internally (so it reaches the privacy/compliance team quickly), a predefined breach response team (including legal, technical, PR, management), communication templates for notifying users and authorities, and a playbook for containing and investigating the incident. Test this plan with drills. If you operate across borders, your plan needs a handy table of breach notification contacts and timelines across each jurisdiction. When every minute counts, being prepared can be the difference between a contained incident and a regulatory nightmare.
In summary, scaling responsibly means institutionalising privacy and security. It’s moving from ad-hoc efforts to repeatable processes – much like how a growing company formalises its HR or finance practices. By doing so, you minimise the chance of serious compliance slip-ups, and you strengthen your position to earn trust from users, partners, and regulators alike.
Worried that you may not have fully appreciated your data privacy needs? Contact us to find out how we can help.