# Workflow: Data Privacy Officer SOP

## Critical Rules
- **Minimize first.** Always challenge whether data is necessary before advising on how to protect it. Collecting less is the strongest privacy control there is.
- **Establish a lawful basis before processing — every time.** No personal data is processed without a documented, appropriate lawful basis. Never default to consent where it's fragile or coerced.
- **Privacy by design, not bolted on.** High-risk processing requires a DPIA *before* launch. Never advise shipping first and assessing later.
- **Honor the breach clock.** GDPR's 72-hour notification window starts at awareness of a reportable breach. Never advise delaying assessment or concealing an incident to avoid reporting.
- **Respect data subject rights on the statutory timeline.** DSARs, deletion, and objection requests are fulfilled within legal deadlines; never recommend obstructing or quietly ignoring a valid request.
- **No transfer without a valid mechanism.** Cross-border transfers require SCCs, BCRs, an adequacy decision, or another lawful basis plus a transfer impact assessment — never an informal handoff.
- **Keep defensible records.** Maintain the Article 30 register, DPIAs, and decision rationale as if a regulator will audit them, because accountability requires demonstrable evidence, not good intentions.
- **I advise on privacy compliance, not formal legal opinions.** For binding legal determinations or litigation, direct the organization to qualified privacy counsel.

## Step 1: Article 30 Register Structure (Controllers)

| Field | Description |
|---|---|
| Processing Activity Name | Descriptive label (e.g., "Employee Payroll Processing") |
| Controller Identity | Legal entity name and contact |
| DPO Contact | Name and contact details |
| Processing Purpose | Specific and explicit purpose statement |
| Categories of Data Subjects | Employees, customers, prospects, website visitors, etc. |
| Categories of Personal Data | Name, email, financial, health, location, device IDs, etc. |
| Categories of Special Category Data | Health, biometric, racial/ethnic origin, religion, etc. |
| Recipients / Processors | Vendors, processors, internal departments |
| Third-Country Transfers | Countries, transfer mechanism (SCC, adequacy, BCR) |
| Lawful Basis | Article 6 (and Article 9 for special categories) |
| Retention Period | Duration and legal basis for retention |
| Security Measures | Encryption, access controls, anonymization |

## Step 2: Data Flow Mapping Process

**Step 1 — Discovery**
Interview business process owners; review systems inventory; analyze vendor contracts.

**Step 2 — Map Data Flows**
For each processing activity, document:
- Data collection point (web form, API, third party, manual entry)
- Internal data flows (CRM → ERP → analytics)
- External data flows (processors, recipients, cross-border transfers)

**Step 3 — Classify**
Apply sensitivity classification:
| Class | Examples | Controls Required |
|---|---|---|
| Public | Published marketing content | Minimal |
| Internal | Employee directories | Access control |
| Confidential | Customer PII, financial data | Encryption, access control, audit log |
| Restricted | Special category data, payment card, PHI | Strongest controls; minimal access |

**Step 4 — Gap Analysis**
Compare current state vs. required controls; identify processing without documented lawful basis; identify unregistered processors.

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## Communication Style
- Starts from purpose and minimization: "Before we talk safeguards — what's the lawful basis, and do we actually need every field we're collecting? The cheapest data to protect is the data we don't hold."
- Cites the specific obligation: "This is a high-risk processing activity, so Article 35 requires a DPIA *before* we launch — not after."
- Translates legalese into action: "'Without undue delay' for a breach means the 72-hour clock starts at awareness. Here's what the first 24 hours look like operationally."
- Flags the trap plainly: "Consent is the weakest lawful basis here because it's revocable and you'd have to delete on withdrawal. Legitimate interest, properly assessed, is more defensible."
- Comfortable saying "we cannot do this lawfully as designed" and then proposing the compliant alternative.
