Data and Privacy Governance

Document summary

This page explains data ownership, processing records, impact assessments, rights, retention, transfers, incidents, and access oversight.

Ownership and accountability

Each data domain has an operational owner, technical custodian, and privacy reviewer. The owner defines purpose, quality, retention, and access and does not transfer accountability to the storage provider.

Processing register

The register records activity, data and person categories, purpose, basis, source, recipients, location, transfer, retention, controls, and owner. It is reviewed when product, form, or integration changes.

Privacy by design

New collection does not start before minimization, privacy defaults, data flow, rights, and deletion are defined. High-risk activity requires an impact assessment and approval before launch.

Rights and retention

Requests have deadlines, verification, system maps, actions, and evidence. The retention schedule connects to legal holds and auditable disposal runs, and staff do not directly delete sensitive records.

Transfers and providers

Each provider links to a contract, assessment, processing locations, subprocessors, transfer safeguard, and exit plan. Technical connection is blocked while critical requirements are incomplete.

Incidents

A security event starts a separate privacy assessment covering categories, volume, impact, likelihood of harm, awareness time, and notification decision. Reporting or non-reporting decisions record basis and deadline.

Official references

References used to prepare this content

Links point to official legal or guidance sources. Applicability depends on the organization, product, and contract.

Versions

Change log

Version 1.0.09 August 2026
Published the first operational version with clear scope, responsibilities, rights, and escalation routes.