DISCRECTION BY DESIGN FOR THE LUXURY SECTOR

A specialist data protection assessment for luxury and premium brands, in store and online

Your clients expect discretion in every interaction with your brand, whether they buy in store, online or through a personal shopper. The Discretion by Design Assessment extends that same discretion to the data they trust you with.

Why it matters 

Your best clients share more than most customers: preferences, sizes, family details, delivery addresses, order histories and gifting occasions. That depth is what makes exceptional service possible, from a personal shopper who remembers every detail to an online experience that feels made for them. It also means that if the data is mishandled, the damage goes beyond a regulatory issue. Your clients' privacy, their security and your reputation are all put at risk.

Personalisation and AI

Personalisation is how premium brands grow, and AI is changing how it's done. Email and SMS flows, product recommendations, e-commerce apps, clienteling tools, AI-drafted outreach, chatbots and lookalike advertising all rely on detailed client profiles. Many of these features are switched on inside platforms you already use, often without anyone checking what data they collect or where it goes.

The assessment maps where profiling and AI are used across your client journey, online and offline. It checks that each use is lawful, transparent and something your clients would expect, so you can personalise with confidence and without the risk of your service feeling intrusive.

What the assessment covers

The assessment reviews how well you manage client data against the UK GDPR, the Data Protection Act 2018 and the Privacy and Electronic Communications Regulations (PECR), as amended by the Data (Use and Access) Act 2025.

It covers all the personal data your business uses, with deeper focus on the areas that matter most to premium brands:

• Lawful basis and data mapping across the client journey, from first visit to repeat purchase
• How you collect data and what you tell clients, at checkout, in store, online and on social media
• Your e-commerce platform and the apps connected to it, including reviews, loyalty and subscription tools
• Cookies, tracking pixels and marketing communications, including email, SMS, WhatsApp and push notifications
• Personalisation, profiling and clienteling
• Use of AI at any stage of the client journey, including staff use of general AI tools such as ChatGPT
• Security systems, including CCTV and internal monitoring software
• Records of processing and accountability, including who can access VIP and high-profile client records
• Data Protection Impact Assessments and high-risk processing
• Client rights, including access requests, deletion and marketing preferences
• Supplier contracts and data sharing, covering fulfilment and delivery partners, marketing agencies, concierge services, stylists, personal shoppers and other third parties handling client data
• Breach readiness and incident response, weighted to the reputational and contractual exposure of a leak involving high-profile clients

For brands selling internationally, the assessment can be extended to cover other jurisdictions.

How it works

The assessment involves scheduled meetings with key people in your business, a review of your website, e-commerce set-up and social media presence, and a review of any existing policies and documentation.

What you get

A maturity rating: a report showing where your business sits on our five-stage data protection maturity scale, from Forming to Leading

• Risks, issues and recommendations: a detailed account of each risk and issue found, including in your use of personalisation and AI, with recommendations on how to fix it that suit your stage of growth
• Clear priorities: risks and issues ranked, so you can be sure you're tackling the biggest ones first
• A 12-month roadmap: what to do, when, and how each step raises your maturity

We prioritise recommendations by risk and commercial benefit, so you can act with confidence.

If you would like support in delivering the roadmap, Tygo's fractional DPO service picks up where the assessment leaves off, giving you senior data protection expertise on a retained basis without the cost of a full-time hire.