Build the Accountability Map
Translate GDPR accountability into a control map with owners, evidence, and independent review.
A privacy policy says what should happen. An accountability map proves who keeps it happening. Owner The business process owner should understand the purpose, fields, users, and exceptions. Privacy can support, but it should not be the only accountable party. Evidence Evidence must be findable: ROPA entry, DPIA, vendor review, retention rule, access approval, audit sample, incident log, or training record. Assurance Use a Three Lines view: first line runs the control, second line sets standards and monitors, third line tests independently. That structure keeps privacy controls from depending on memory.
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