Digital Personal Data Protection Act · Control SC-003 · Priority: high · Component: Scope & Classification

What this control covers

Formally designate the organisation as Data Fiduciary at board level. Maintain a Record of Processing Activities (ROPA) covering all personal data processing - specifying purpose, legal basis, data categories, recipients, retention periods, and transfers. Objective: Establish clear organisational accountability as Data Fiduciary and provide a comprehensive audit trail of all processing activities.

Why it matters

Risk is the language an executive team understands; this control connects technical reality to board-level decisions and budget allocation.

How to implement

AWS

Codify the policy intent as SCPs, AWS Config conformance packs, and Security Hub standards so the cloud enforces what the document says.

Azure

Codify in Azure Policy initiatives (built-in regulatory compliance for CIS, ISO 27001, SOC 2, HIPAA) and assign at management-group level.

GCP

Use Cloud KMS with customer-managed encryption keys (CMEK) for BigQuery, GCS, and Compute. Sensitive Data Protection (DLP API) inspects/de-identifies PII at scale.

Google Workspace

Enable client-side encryption for Drive/Docs and turn on Drive Labels + DLP rules to prevent external sharing of regulated data classes.

On-premises

Maintain a policy library with a documented review cadence (annual minimum); store in your GRC tool with attestation tracking. Map each policy to controls so an audit pull cites the exact policy clause.

Evidence to collect

  • policy_document — A signed, version-controlled policy stating leadership intent and the named owner.

Signed policies, procedures, and registers document the safeguard. Focus: Data Fiduciary Role Assignment & ROPA.

Quick checklist

  • Maintain — Data Fiduciary Role Assignment / Ropa
  • Designate — Data Fiduciary Role Assignment / Ropa
  • Provide — Data Fiduciary Role Assignment / Ropa

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