Solution · Data Protection & Privacy
Know Your Data, Protect It and Prove It.
The Challenge
Personal and sensitive data now flows across cloud services, suppliers and borders.
The Outcome
- Demonstrable compliance with data protection law
- Lower breach exposure
- Customer trust in data handling
Executive Summary
- 01A data inventory is the foundation of privacy work, because controls placed without knowing where personal data lives protect the wrong things.
- 02Lawful basis, classification and encryption must be linked, so that each legal obligation becomes a specific technical setting.
- 03Evidence matters as much as the control, since regulators and auditors ask for records rather than intentions.
The Challenge
Personal and sensitive data now flows across cloud services, suppliers and borders.
Regulators expect organizations to demonstrate where data lives, why it is processed and how it is protected.
The DAAKYI Approach
DAAKYI pairs privacy governance with engineering: inventory and lawful‑basis work on one side, classification, loss prevention and encryption on the other.
Cross-border transfers are mapped and controlled.
Delivered Through These DAAKYI Services
Relevant industries
- 01
Privacy maturity assessment
- 02
Data inventory and governance
- 03
Classification, DLP and encryption
- 04
Cross-border data controls
In Depth
How the Solution Comes Together
Start with a Living Data Inventory
A data inventory records what personal data an organization holds, where it sits, who touches it and why it is processed. It is built from system owners, data flow diagrams and discovery scans, not from a single questionnaire. Each processing activity is linked to a purpose and a lawful basis. Under Act 843, that link supports the principles of specification of purpose and lawfulness of processing. The inventory must change when a new SaaS tool, supplier or integration appears. A static spreadsheet goes stale quickly, and stale records give regulators and auditors a reason to doubt every other answer.
Classify So Controls Follow Data
Classification turns legal categories into handling rules. A small set of sensitivity labels, such as public, internal, confidential and special category, is easier to enforce than a long scheme nobody remembers. Labels drive technical behavior: which data may leave a tenant, which requires encryption with customer-managed keys, which triggers a loss prevention block. Health records, financial identifiers and children's data usually sit at the top tier. Labels should be applied automatically where content patterns are reliable and by users where context matters. The goal is consistency. When the same record is treated differently in email, storage and analytics, the weakest path defines the real protection.
Prove It with Operating Evidence
Accountability is a legal principle under Act 843 and a design requirement everywhere else. Evidence means records of processing, impact assessments, transfer decisions, access reviews, key management logs and breach procedures that were actually tested. Collect it as a by-product of operating controls rather than in a scramble before an audit. A breach clock makes this concrete: GDPR expects notification to the supervisory authority within 72 hours where feasible, unless the breach is unlikely to result in risk. Meeting that window depends on knowing, within hours, what data was in the affected system and whose it was. The inventory and classification work answers that question.
Privacy law is written as obligations. Breaches are decided by configurations. The work is translating one into the other.
Capability Matrix
What the Service Includes
Privacy Governance
Roles, policies, processing records.
Data Classification
Sensitivity labels and handling.
Loss Prevention and Encryption
Controls that follow the data.
Cross‑Border Governance
Transfers mapped and controlled.
Operating Model
Delivered from the GUIDE · SECURE · OPERATE Pillar
Pillar position
GUIDE · SECURE · OPERATE
Delivered across all three pillars
Engagement model
Advisory Engagements
Fixed-scope assessments, strategy, compliance and testing.
Best for · Defined questions with a clear deliverable
Engagement model
Project Implementation
Design and deployment of security technologies.
Best for · Modernization and transformation
Threat Scenarios
What It Looks Like in Practice
Shadow SaaS Holding Customer Data
How It Shows Up
Staff upload customer exports to an unsanctioned tool. It surfaces in DNS logs, proxy data or expense claims, not in the inventory.
Response
Discover the tool, add it to the inventory and decide its lawful basis. Then onboard it with a contract and controls, or block it.
Unmapped Cross‑Border Transfer
How It Shows Up
A supplier's support team or sub-processor in another country can query production data, and nobody recorded the transfer.
Response
Map the transfer, document the legal mechanism and restrict access. Where residency is required, keep the data in-country and limit remote support to masked copies.
Over‑Shared Health Record
How It Shows Up
Loss prevention alerts show patient identifiers in outbound email or in a link open to anyone.
Response
Block the channel, tighten sharing defaults and assess whether the incident triggers notification under HIPAA or Act 843.
Stolen Credentials Reach a Data Store
How It Shows Up
A service account performs unusual bulk reads against a customer database outside its normal pattern.
Response
Revoke the credential and use access logs and the inventory to scope affected records. Encryption with separate key custody limits what the account could read.
| Scenario | How It Shows Up | Response |
|---|---|---|
| Shadow SaaS Holding Customer Data | Staff upload customer exports to an unsanctioned tool. It surfaces in DNS logs, proxy data or expense claims, not in the inventory. | Discover the tool, add it to the inventory and decide its lawful basis. Then onboard it with a contract and controls, or block it. |
| Unmapped Cross‑Border Transfer | A supplier's support team or sub-processor in another country can query production data, and nobody recorded the transfer. | Map the transfer, document the legal mechanism and restrict access. Where residency is required, keep the data in-country and limit remote support to masked copies. |
| Over‑Shared Health Record | Loss prevention alerts show patient identifiers in outbound email or in a link open to anyone. | Block the channel, tighten sharing defaults and assess whether the incident triggers notification under HIPAA or Act 843. |
| Stolen Credentials Reach a Data Store | A service account performs unusual bulk reads against a customer database outside its normal pattern. | Revoke the credential and use access logs and the inventory to scope affected records. Encryption with separate key custody limits what the account could read. |
Outcomes
What Your Institution Gains
- Demonstrable compliance with data protection law
- Lower breach exposure
- Customer trust in data handling
Methodology
The Method, Step by Step
- 1
Scope Processing Activities
List every business process that handles personal data, with its owner, purpose and systems. Include HR, marketing, support and analytics, not only core products. The output is a scoped register that defines what the rest of the work must cover and what is explicitly excluded.
- 2
Map Data Flows
Trace how data enters, moves, is shared and leaves. Record suppliers, sub-processors, storage locations and transfer destinations. Validate the diagrams against discovery scans and network evidence, because teams often describe the intended flow rather than the actual one.
- 3
Assign Basis and Ownership
For each activity, document the lawful basis, retention period and accountable owner. Flag processing that lacks a clear basis, collects more than its purpose needs or is kept longer than necessary. These gaps become the first remediation items.
- 4
Engineer the Controls
Translate decisions into settings: labels, loss prevention rules, encryption and key custody, access scoping, masking and transfer restrictions. Each control is tied to the obligation it satisfies, so an auditor can follow the line from law to configuration.
- 5
Test and Evidence
Verify that controls work by sending test records through each channel, reviewing access, rehearsing breach scoping and checking transfer restrictions. Store results with dates and owners. Repeat on a schedule and whenever processing changes materially.
How It Works
How Data Protection & Privacy Comes Together
- 01Inventory
- 02Govern
- 03Protect
- 04Evidence
Regulatory & Industry Context
The Obligations This Service Supports
Addresses Act 843, GDPR, HIPAA, the Nigeria Data Protection Act and ISO/IEC 27701.
Frameworks DAAKYI helps clients implement
- Ghana Act 843
- GDPR
- HIPAA
- Nigeria Data Protection Act
- ISO/IEC 27701
Framework references describe client implementation support, not DAAKYI certifications.
Deliverables and Roles
What You Receive, and Who Does What
| Deliverable | Purpose |
|---|---|
| Data Inventory and Record of Processing | Gives a single, current account of what personal data is held, where, why and by whom. |
| Classification Scheme and Handling Standard | Defines labels and the exact handling rule attached to each one. |
| Cross‑Border Transfer Register | Documents each transfer, its destination, its legal mechanism and the safeguards applied. |
| Impact Assessments for High‑Risk Processing | Records risks to individuals and the measures chosen to reduce them before processing begins. |
| Control Evidence Pack | Collects test results, access reviews and key logs that demonstrate controls operate as described. |
| Role | Responsibility |
|---|---|
| Data Protection Officer or Privacy Lead (Client) | Owns the record of processing, advises on lawful basis and acts as the contact point for the regulator. |
| Business Data Owner (Client) | Decides purpose, access and retention for the data their function creates and answers for it. |
| Security Architect (Provider) | Designs classification, encryption, key custody and loss prevention so they match the documented obligations. |
| Privacy Consultant (Provider) | Runs the inventory, assessments and gap analysis against the applicable laws and standards. |
Maturity Model
Where Organizations Typically Stand
Stage 1
Ad Hoc
Personal data locations are known only informally. Controls exist in places but are not linked to any legal obligation.
Stage 2
Documented
A record of processing and policies exist and owners are named. Enforcement still depends on people following the rules.
Stage 3
Enforced
Labels, encryption and loss prevention apply automatically. Transfers are restricted by technical means, not only by contract.
Stage 4
Measured
Coverage, exceptions and incident scoping are tracked over time. Evidence is produced continuously and reviewed by leadership.
Frameworks and Regulation
The Standards That Shape This Work
Ghana Data Protection Act, 2012 (Act 843)
Established the Data Protection Commission, requires data controllers to register and sets eight privacy principles, including accountability, purpose specification and data security safeguards.
GDPR
Applies to organizations handling data of people in the EU. It requires breach notification to the supervisory authority within 72 hours where feasible, unless the breach is unlikely to result in risk.
HIPAA Security Rule
Requires administrative, physical and technical safeguards for electronic protected health information, which maps directly to access control, encryption and audit logging.
ISO/IEC 27701
Extends an information security management system with privacy information management requirements, giving a certifiable structure for roles, records and controls.
Buyer Guidance
Choosing the Right Provider
What to look for
- Look for a provider that can show how a specific legal obligation becomes a specific control setting.
- Look for engineers and privacy specialists working from the same inventory rather than separate documents.
- Look for experience with the laws you actually face, including Act 843 and any foreign rules that reach your data.
- Look for deliverables you can hand to a regulator or auditor without rewriting them.
Questions to ask a provider
- How do you keep the data inventory current after the engagement ends?
- Which controls will block data movement, and which will only alert?
- How do you handle transfers to suppliers and sub-processors in other jurisdictions?
- What evidence will we hold to show each control operates as intended?
Technical Detail
For Architects and Security Leads
Encryption and Key Custody Design
Encryption is only as strong as the control over its keys. A common pattern is envelope encryption: data is encrypted with data keys, and those keys are wrapped by a master key held in a key management service or hardware security module. Separate duties so that administrators of storage cannot also export keys. Use customer-managed keys for the most sensitive classes, so access can be revoked without moving data. Rotate keys on a defined schedule and log every use. Plan recovery before deployment, because a lost key makes backups unreadable. Encrypt in transit with current TLS and encrypt at rest on every tier, including backups and analytics copies.
Tuning Loss Prevention Policies
Loss prevention fails when it is noisy, so policy design matters more than product choice. Start in monitor mode and review matches before enforcing. Combine pattern matching with validation, such as checksum tests on identifiers, to cut false positives. Use exact data matching or document fingerprinting for high-value records like patient lists. Cover each channel separately: email, endpoint, web upload, cloud storage and messaging. Tie rules to classification labels so a confidential label changes what a user may do. Move to blocking for narrow, well-tested cases first, and give users a justified override that is logged and reviewed. Measure false positives and bypasses every cycle.
Glossary
Key Terms
- Lawful Basis
- The legal justification, such as consent, contract or legal obligation, that permits a specific processing activity.
- Data Residency
- A requirement or decision that data be stored and processed within a defined country or region.
- Pseudonymization
- Replacing direct identifiers with substitutes so data cannot be attributed to a person without separately held additional information.
- Data Protection Impact Assessment
- A structured review of the risks that high-risk processing poses to individuals, and of the measures chosen to reduce them.
Related
Explore Connected Capabilities
Proof Points
What We Can Stand Behind
- Every stage of DAAKYI's delivery methodology produces documented, auditable deliverables.
FAQ
Questions Leaders Ask
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