unisphere at the old World's Fair grounds in Flushing, Queens
PHOTO: Ajay Suresh

We are living in a time of unprecedented complexity. Organizations have finally realized that survival in the digital age requires a balancing act between personalization and privacy, all while navigating sometimes conflicting sets of national and local regulations.

In addition, there’s a growing preference among consumers for local communities, products, customs and cultures. This preference for localization is especially strong in consumer goods industries (think cosmetics and food and beverage). Adding to that complexity are countries like India, with a large and diverse population, where there’s a trend toward hyperlocalization, sometimes going to the city level.

A natural response to complexity is the desire to increase control, but it isn't always a good one. Which is where the digital policy steward comes in. The digital policy steward finds the delicate balance between where headquarters has the final say and where relinquishing some control to local teams will pay off.

The Evolving Role of the Digital Policy Steward

Strategic decisions — like whether or not it makes sense to operate in a given market (due to things like intellectual property rights, restrictions on data transmission, etc.) — rightly belong to the C-suite. So do decisions about whether to localize the company’s products. In India, for example, Coca-Cola is shifting from carbonated beverages to fruit-based drinks, using ingredients indigenous to India.

Other decisions, however — like branding, translation, etc. — belong to the digital policy steward. And it’s time to take a good look at whether your existing digital policies need to evolve to keep up with changing customer preferences. While I can’t promise you there won’t be any bumps, I’m going to provide a practical approach that will make things a lot easier. You’ll still probably have to deal with territorial egos, resistance to change, and maybe even cultural misunderstandings within your own organization, but it’s definitely doable.

Related Article: How to Overcome Resistance to Digital Policies and Standards

Whatever You Do, Don’t Start Over

In other words: You’ve got this. If your organization has established the position of digital policy steward, the hard part — agreeing that the organization needs digital policies and deciding who will make decisions regarding those policies — has already been done. Don’t make the mistake of thinking you have to start all over on the multinational front, because that will make your job a million times harder. Instead, just expand the job you already have to include your global operations.

Let me walk you through it.

How to Take Your Organization’s Digital Policies Global

Let me repeat: If you’re the digital policy steward, you already have this responsibility. So instead of asking for permission to reconsider your policies in light of your global operations ... just do it.

Step 1: Identify digital policy decisions that should always be made at the headquarters level

To do this, start at the very top. Identify the digital policies that are absolutely not subject to change or alteration, no matter what. Marketing-related examples could include:

  • The shape of your logo.
  • Accessibility standards.
  • Security standards.
  • Your commitment to privacy.
  • What type of user-generated content (UGC) you’ll accept and what type of consent you’ll gather from the user.
  • If you work for a public organization, the inclusion of required financial information.
  • Copyrights and trademarks.
  • If needed, a statement that your website is not intended for citizens of certain countries (For example, the US is one of the few countries that allows pharmaceutical companies to market drugs directly to consumers. Because of that, they have to try to prevent citizens of other countries from using their US site.).

Moving on to the technical side of things, your non-negotiables may include:

  • How your organization will handle the transmission of customer data across national borders (including how you’ll work with countries like China, which requires its citizens’ data to be stored on servers within its national borders).
  • Which, if any, regional data transfer agreements your organization will recognize.
  • To what degree the organization will comply with multiple sets of national laws vs. complying with the laws most important to the organization’s strategy and hoping for the best with the rest.
  • Whether and how your organization needs to verify users’ age to restrict access by children.
  • Standards for vetting vendors (both direct and third-party).
  • Standards for evaluating investments in technologies like 5G, AI, machine learning, etc.
  • Which countries are approved for sourcing hardware, cloud services, etc. — and which are not.
  • Which countries, if any, your organization won’t sell its digital products to.

Once you’ve singled out policies that should always be made at headquarters, it’s time to look at the rest.

Related Article: Think Globally, But Act Locally With Information Management

Step 2: Identify policies that should be made — at least to some degree — at the local level

For most multinationals, it’s risky to retain control of all digital policy decisions at headquarters. After all, no matter how much your legal team researches regulations in all the countries where you do business, they’ll never understand local business customs like the locals do. The same is true for your marketing department: You can’t just use Google Translate and expect your efforts to resonate with local audiences.

Once you accept that the majority of your existing digital policies may apply only to your American market, you can start the hard work of deciding which digital policy decisions should be shared with (or made by) local markets.

Beware, though — it’s not always that simple. Sometimes you’ll find that one part of a policy should be localized white another part should remain at headquarters. Take a look at these examples:


Cultural differences can affect SEO results, even when searchers speak the same language. Marketers in the travel industry know, for example, that Americans go on “vacation” while the British go on “holiday.” Now imagine adding a dozen or more different languages to the mix. Local teams will know exactly which search terms will lead users to your intended landing page.

In addition, different search engines use different factors to generate page results. American marketers are used to “working for Google,” but people in some countries prefer Yandex (popular in Russia), Baidu (popular in China), and Bing, all of which may (gasp!) use different ranking criteria than Google. Again, local teams will be best equipped to optimize your content for the search engine locals prefer.

On the other hand: Site structure can also be an important factor in local SEO success. So, while you might let local teams make decisions about search terms, you may decide that decisions about site structure (such as whether to have a single website or separate websites for each country) may be better left to the digital team at headquarters.


Google Translate boasts the ability to translate between English and over 100 other languages. But many languages use multiple words to describe the same thing, and one word can have multiple meanings. In addition, direct translations that don’t account for nuances can cause all kinds of problems. During the height of the Cold War, for example, Nikita Khrushchev gave a speech that included a phrase, that when translated word-for-word from Russian, was “We will bury you.” It didn’t take much to ratchet up tensions back then, and those words came across as a direct threat. The correct, nuanced translation, however, was “We will outlast you” — more “trash talk” than threat!

That’s why so many companies are moving toward localized content creation. Some organizations have their localized teams develop content from scratch to appeal to local interests and customers, while others choose to have the meaning of the original content translated into the local language by people who understand how nuance and cultural differences come into play.

Such nuances can affect page layout as well: Hebrew and Arabic, for example, are read right to left, while Japanese is vertical.

On the other hand: Organizations may decide to leave decisions about the hierarchical structures used to indicate language — as well as other indicators like hreflang tags — to headquarters to maintain site consistency.


Preferences for colors, fashion, etc., can vary drastically from one country to another. Many organizations wisely decide to let local teams use local models, and to photograph them in a way that represents the culture’s norms. A cosmetics company operating in Saudi Arabia, for instance, might leave it to the local team to decide whether models should wear a hijab.

Different cultural myths and symbolisms also come into play. For example, imagine how puzzled Japanese shoppers must have been when Pampers diapers first arrived on their shelves, in boxes adorned with pictures of storks delivering babies. (In Japan, babies are delivered by giant, floating peaches!)

On the other hand: Organizations may decide to make decisions with political implications in the C-suite. At any given time, there are any number of social movements around the globe. Decisions about whether the organization should choose a side — or the best way to remain neutral — belong at headquarters.


Believe it or not, Instagram, Snapchat and LinkedIn aren’t universal favorites. Channels that resonate with your US customers might not be as successful in other countries due to nuances that only a local would know. For example, many people in Japan hesitate to use LinkedIn because they’re afraid their employer will think they’re looking for another job, something frowned upon by Japanese employers. And in China, the preferred channel is WeChat, so marketers would miss that audience if digital policies only allowed them to use Facebook or Twitter. It’s another example of why localized marketing teams are often more successful: They have a deeper knowledge of which channels are successful as well as best practices for using them.

On the other hand: IT may have concerns about the security of some channels and advise the organization to avoid them.

Related Article: Translation, Localization, Transcreation: What's the Difference?

Step 3: Prepare to get feedback from your peers in other countries

Now it’s time to get input from the people best suited to make suggestions on localization: your local teams.

Unless your organization is already very decentralized, your best sources may not be digital policy stewards (lucky for you if they are!). Instead, they might be the heads of localized marketing departments or members of the local legal team.

I think the best way to get feedback is to use Google Sheets to create a table you can use to get feedback on each policy (minus those you’ve decided will always be made at headquarters). It should look something like this:


Headquarters, local, or both?

Comments and suggestions







Don’t forget to write detailed instructions for exactly what you’re asking the recipients to do. For example, ask them to provide as much information as they can as to why a particular policy might not work in their country as well as their suggestions for how to change it.

Step 4: Send the feedback survey to one or more contacts in each country where you operate, as well as to relevant stakeholders at headquarters (IT, legal, etc.)

Send the survey and your instructions out to the masses!

As feedback comes in, gather it into one document. In some cases, you may need to make some follow-up phone calls to get more information.

Step 5: Get to work updating your digital policies

Some of these decisions seem obvious at first — like letting local teams customize content instead of using an automatically generated translation. And that’s probably the right decision. But remember that, for some, you’ll need to involve other functional areas, like coordinating with IT on things like hreflang tags. Using the examples above as a guide, go through each policy to decide the degree of and process for localization.


Remember, you’ll have to document all of your digital policy updates in detail, including the changes that were made by country. A few tips for documentation:

  • Include the date the policy was changed.
  • Describe the reason for localization decisions.
  • Identify the contacts you worked with for each localized team.
  • If any special approvals were needed, include the name and position of the person who gave the approval, as well as the date it happened.

And don’t forget to add all of the updates to your digital repository!

Step 6: Communicate the new localization policies throughout the organization.

By this time, you’ll have already put in so much work your head is spinning! But things are just beginning for the folks who have to implement these changes. In some cases, the way they do their work will change dramatically.

The simplest way to accomplish this is to draft a message explaining why your organization has chosen to “go local” and directing everyone to the updated digital policies. It would also be a good idea to include contact information (preferably your own) for anyone who has questions.

Going Global in a World That’s Becoming More Local

Things change, sometimes quickly. When digital commerce first exploded, things were so complex and changing so fast that businesses instinctively responded by trying to control the chaos as much as possible. Things are still changing fast, and will continue to do so, but consumers have made it clear that they want customized, personalized messaging, not just a superficial version of American content.

The challenge for today’s digital policy stewards is to figure out the best way to share decision-making, loosening the reins enough to engage consumers without completely giving up control of branding, security, etc. I hope this guide will help you meet the challenge.