FOCUS 01Data use and provenance
Build a data-lineage map from collection through storage, transformation and external sharing. Mark personal, confidential, licensed, public and generated data separately; record the authority relied on for each intended use and the point at which rights may expire.
FOCUS 02Sharing, transfer and retention
Data-sharing arrangements should state permitted purpose, permitted recipients, access controls, retention, deletion, onward transfers and restrictions on model training or re-identification. Commercial value is shaped by these restrictions rather than separate from them.
FOCUS 03DPIA and incident workflow support
Operational governance translates privacy and contractual risks into roles, data minimization decisions, access reviews, impact assessment triggers, deletion testing and incident escalation. The applicable local obligations must be checked against the actual jurisdictions and processing facts.