Global Civil Society Network: Data protection health check
The Client is a global, membership-based civil society network.
Running a global organisation with cross-border operations means being subject to overlapping data protection regimes, each with distinct territorial scope, governance expectations, and processing requirements.
Operating in EMEA and the Americas, our client processes member and stakeholder data at scale across several offices and corporate tools. The client sought a clear view of applicable legal frameworks, identification of existing gaps against those frameworks, and support to implement key requirements and elevate compliance across the organisation. The client needed a bespoke assessment to (i) identify which laws apply to their data processing, (ii) benchmark current practice against core obligations, and (iii) prioritise actions that reduce risk for members and staff while enabling mission delivery.
AWO was asked by a global, membership-based civil society network to to assess its data protection posture across multiple jurisdictions.
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Mapping applicable legal frameworks
We mapped the territorial scope of each framework to the client’s operations, confirming the applicability of several data protection regimes across EMEA and the Americas.
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Gap analysis against core requirements
Through document review and targeted interviews, we benchmarked the client’s current operations against key obligations, providing a concise “status dashboard”.
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Remediation planning and implementation
We translated findings into a prioritised action plan and provided direct support to implement immediate changes, to significantly improve the organisation’s compliance posture.
Alongside this, we considered:
- Records of Processing Activities (ROPA)
- Legal bases and linkage to purposes
- Governance roles (e.g., Data Protection Officer)
- Legal representative (e.g., EU representative for non-EU controllers with processing activities in the EU)
- International data transfers
- Other data protection documentation (e.g., privacy notices, data protection/security policy, and data transfer language)
By providing a ROPA template and a training session for staff from several departments on how to complete it; drafting data breach response and data subject request management plans for organisation-wide use; and a debrief meeting to provide the client with an overview of the project’s findings and deliverables, as well as guidance on the next steps to further improve its compliance posture.
The client obtained:
- a clear baseline assessment of its compliance posture across different legal regimes,
- a practical plan to elevate protections for members, partners, and staff, and
- timely support to implement immediate changes, reducing the overall compliance risk while supporting resilient, mission critical data flows.