Establish governance and accountability

Establish Governance and Accountability

Governance and accountability ensure that compliance is not just a technical fix but a company-wide responsibility. GDPR and CPRA both require organizations to demonstrate that they manage personal data responsibly, document decisions, and assign clear roles for privacy oversight.

Assigning Roles and Responsibilities

Every team member should know their part in protecting data.

• Appoint a Data Protection Officer (DPO) where required.

• Define responsibilities for product, engineering, and legal teams.

• Ensure executives take ownership of compliance strategy.

Documenting Policies and Procedures

Compliance must be written down and auditable.

• Maintain internal privacy policies and standard operating procedures.

• Record how decisions are made regarding data collection and use.

• Keep audit logs and governance documents easily accessible.

Demonstrating Accountability

Show regulators and customers that privacy is taken seriously.

• Maintain a record of processing activities (RoPA).

• Perform Data Protection Impact Assessments (DPIAs) where needed.

• Review compliance posture regularly and update documents.

Example: DPO Role in a SaaS Company

A SaaS startup appoints a Privacy Lead to act as its DPO. This person coordinates DSAR responses, reviews vendor DPAs, and works with engineering to ensure retention rules are enforced. The role is documented in company policies and reported to leadership quarterly.

Implementing Governance in Practice

Policy repository in Git

# Store privacy policies and SOPs in version control
git add policies/*
git commit -m "Update data retention SOP"
git push origin main

RoPA table structure

CREATE TABLE record_of_processing (
  id SERIAL PRIMARY KEY,
  process_name TEXT,
  data_categories TEXT,
  purpose TEXT,
  legal_basis TEXT,
  retention_period TEXT,
  owner TEXT
);

Quarterly review reminder

# Cron job to remind compliance team every quarter
0 9 1 */3 * ./send_compliance_review_reminder.sh

Quick Governance Checklist

• Appoint a DPO or privacy lead if required

• Assign data protection responsibilities across teams

• Maintain documented policies and procedures

• Keep a record of processing activities (RoPA)

• Schedule regular compliance reviews and updates

Conclusion

Establishing governance and accountability creates the structure that keeps compliance sustainable. By assigning roles, documenting policies, and proving decisions, organizations build trust with regulators and customers while embedding privacy into their culture.