Preparing for Significant Data Fiduciary duties

Section 10 provides for additional obligations where a Data Fiduciary is notified as significant. Businesses with large-scale or sensitive processing should understand operational implications before designation becomes urgent.

Preparedness areas

• responsibility and reporting arrangements for a Data Protection Officer;
• independent data auditor readiness;
• data protection impact assessment practices; and
• periodic audit evidence and remediation tracking.

Readiness is easier where documentation and decision ownership already exist across product, security and legal teams.