Solution · Regulatory Compliance & Digital Trust
Earn the Trust That Regulators and Customers Require.
The Challenge
Regulated institutions now face overlapping obligations from cybersecurity law, data protection authorities, central banks and international standards.
The Outcome
- Audit-ready compliance
- Confidence before regulator reviews
- Security assurance customers accept
Executive Summary
- 01One obligation register can serve several regulators when each requirement links to a shared, tested control.
- 02Assurance is credible only when every control has an owner, a test and dated evidence.
- 03Certification and regulator reviews become routine once evidence is collected continuously instead of rebuilt before audits.
The Challenge
Regulated institutions now face overlapping obligations from cybersecurity law, data protection authorities, central banks and international standards.
Customers and partners increasingly ask for proof of security before they sign.
The DAAKYI Approach
DAAKYI builds a single obligation map, closes control gaps and prepares you for certification and regulator review.
Evidence workflows and GRC tooling keep assurance current between audits.
Delivered Through These DAAKYI Services
- 01
Obligation mapping across jurisdictions
- 02
Gap assessment and remediation
- 03
Certification readiness
- 04
Continuous evidence and reporting
In Depth
How the Solution Comes Together
Map Once, Satisfy Many Regimes
Different regimes repeat the same ideas: access control, logging, incident reporting, vendor oversight and retention. Mapping breaks each statute or standard clause into a testable requirement. Each requirement then links to a shared control set. One control, such as privileged access review, can answer a clause in Act 1038, a PCI DSS requirement and an ISO/IEC 27001 Annex A control at once. Differences stay visible. Where a regulator sets a stricter deadline or a narrower scope, the register records that exception rather than flattening it into a generic statement.
Controls Need Owners and Tests
A control that exists only in a policy is not assurance. Each control needs a named owner, a defined frequency, an evidence type and a clear pass condition. Technical controls, such as encryption settings or log retention, can be tested through configuration exports. Process controls, such as access reviews, need dated records with approvers. Weaknesses usually sit in handoffs, for example when HR offboarding never reaches the identity team. Testing the handoff, not just the written procedure, shows whether the control actually operates day to day.
Evidence Should Outlast the Audit
Point-in-time audits reward preparation sprints. Continuous evidence reverses that habit. Records are captured as work happens: tickets, approvals, scan results, training completions and change logs. Auditors then sample from a standing record instead of asking teams to reconstruct the past. Drift becomes visible when a control fails its scheduled test, and each exception is logged with an owner and a due date. Management reviews use the same data, so leaders attest to what the record shows rather than to what teams remember.

A control you cannot evidence is a control a regulator, auditor or customer will treat as missing.
Capability Matrix
What the Service Includes
Obligation Register
Every requirement mapped to controls.
Certification Readiness
ISO/IEC 27001, 27701 and 22301.
Evidence Workflow
Proof available on request.
Trust Reporting
Assurance packaged for customers.
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
Overlapping Regulator Requests
How It Shows Up
A central bank, a data protection authority and a customer each ask for similar proof in different formats.
Response
Answer from the obligation register so each request draws on the same tested controls and evidence.
Failed Customer Security Review
How It Shows Up
A prospect's questionnaire stalls because answers are inconsistent or unsupported by documents.
Response
Maintain approved, evidence-backed answers tied to specific controls, so responses stay consistent and verifiable.
Reportable Breach with Unclear Duties
How It Shows Up
An incident touches personal data, and teams disagree on who must be notified and when.
Response
Use a pre-built notification matrix that links each regime's trigger and deadline to a decision owner.
Audit‑Season Control Decay
How It Shows Up
Access reviews and backup tests were done once, then lapsed, and gaps surface only during fieldwork.
Response
Schedule control tests, alert owners on missed runs and record remediation before an auditor finds the gap.
| Scenario | How It Shows Up | Response |
|---|---|---|
| Overlapping Regulator Requests | A central bank, a data protection authority and a customer each ask for similar proof in different formats. | Answer from the obligation register so each request draws on the same tested controls and evidence. |
| Failed Customer Security Review | A prospect's questionnaire stalls because answers are inconsistent or unsupported by documents. | Maintain approved, evidence-backed answers tied to specific controls, so responses stay consistent and verifiable. |
| Reportable Breach with Unclear Duties | An incident touches personal data, and teams disagree on who must be notified and when. | Use a pre-built notification matrix that links each regime's trigger and deadline to a decision owner. |
| Audit‑Season Control Decay | Access reviews and backup tests were done once, then lapsed, and gaps surface only during fieldwork. | Schedule control tests, alert owners on missed runs and record remediation before an auditor finds the gap. |
Outcomes
What Your Institution Gains
- Audit-ready compliance
- Confidence before regulator reviews
- Security assurance customers accept
Methodology
The Method, Step by Step
- 1
Define Scope and Obligations
Identify the legal entities, systems, data types and jurisdictions in scope. Collect every applicable statute, directive, contract clause and standard. Record each source with its clause reference so later reviewers can trace any control back to the obligation that justifies it.
- 2
Build the Control Crosswalk
Translate obligations into discrete requirements and link them to a common control library. Remove duplicates, flag conflicts and note where one regime is stricter. The result is a single register that shows which controls satisfy which obligations and where nothing yet applies.
- 3
Assess Control Design
Compare documented controls against requirements through interviews and document review. Ask whether each control is defined, owned and capable of meeting its requirement. Rate gaps by regulatory exposure and likelihood of failure, so remediation effort follows consequence instead of convenience.
- 4
Test Operating Effectiveness
Sample real records to confirm controls actually run. Check access reviews, restore tests, patch records and training logs against stated frequency. Separate design gaps from operating failures, since they need different fixes: new process for the first, discipline and tooling for the second.
- 5
Remediate and Attest
Assign each gap an owner, a fix and a due date. Retest after closure and store the proof. Prepare management attestations, internal audit results and the evidence packs that certification bodies and regulators will request, organized by obligation rather than by team.
How It Works
How Regulatory Compliance & Digital Trust Comes Together
- 01Map
- 02Assess
- 03Remediate
- 04Evidence
Regulatory & Industry Context
The Obligations This Service Supports
Covers Act 1038, Act 843, UAE NESA, the Nigeria Data Protection Act, ISO/IEC 27001, SOC 2, PCI DSS and GDPR.
Frameworks DAAKYI helps clients implement
- Ghana Act 1038
- Ghana Act 843
- UAE NESA
- Nigeria Data Protection Act
- ISO/IEC 27001
- SOC 2
- PCI DSS
- GDPR
Framework references describe client implementation support, not DAAKYI certifications.
Deliverables and Roles
What You Receive, and Who Does What
| Deliverable | Purpose |
|---|---|
| Obligation Register | Lists every requirement with its source clause, linked controls and accountable owner. |
| Control Gap Report | Ranks design and operating failures by regulatory exposure. |
| Statement of Applicability | Records which ISO/IEC 27001 Annex A controls apply and why. |
| Evidence Index | Points auditors to the record proving each control operated. |
| Remediation Tracker | Shows each gap's owner, fix, due date and retest result. |
| Role | Responsibility |
|---|---|
| Chief Information Security Officer | Owns the control framework and signs off on residual risk. |
| Data Protection Officer | Interprets privacy obligations and advises on notification decisions. |
| Control Owner | Runs a specific control on schedule and supplies its evidence. |
| Compliance Advisor | Maintains the mapping and challenges evidence quality before auditors do. |
Maturity Model
Where Organizations Typically Stand
Stage 1
Reactive
Compliance work starts when an audit or customer request arrives. Evidence is gathered by hand, and answers differ between teams.
Stage 2
Documented
Policies and a basic register exist. Ownership is defined, but testing is irregular and proof is scattered.
Stage 3
Managed
Controls run on schedule with owners and dated records. Gaps are tracked to closure across all regimes.
Stage 4
Continuous
Evidence flows automatically and failures trigger alerts. Leadership reviews live assurance and uses it in sales.
Frameworks and Regulation
The Standards That Shape This Work
ISO/IEC 27001:2022 and 27002
Annex A holds 93 controls in four themes: organizational, people, physical and technological. ISO/IEC 27002 supplies implementation guidance and often serves as the shared control library.
PCI DSS v4.0.1
Cardholder environments must meet its requirements, including those future-dated items that became mandatory on 31 March 2025. Scope definition drives most of the effort.
NIST CSF 2.0
Its six functions (Govern, Identify, Protect, Detect, Respond, Recover) give executives a common language for presenting control coverage to boards.
Ghana Act 843 and Act 1038
Act 843 sets eight privacy principles and controller registration. Act 1038 covers critical information infrastructure, accreditation of providers and incident reporting.
Buyer Guidance
Choosing the Right Provider
What to look for
- Look for a single mapping method that handles several regimes without duplicating work.
- Insist on deliverables you can keep and maintain after the engagement ends.
- Expect clear separation between advising on readiness and certifying, which only accredited bodies do.
- Check that findings are ranked by regulatory consequence, not just technical severity.
Questions to ask a provider
- How do you record conflicts between regimes?
- Who owns the register afterward?
- How do you test operation, not just design?
- What evidence format will auditors accept?
Technical Detail
For Architects and Security Leads
Designing a Control Crosswalk Data Model
Treat the register as structured data, not a spreadsheet narrative. Each record needs an obligation ID, source instrument, clause reference, requirement text, jurisdiction, control ID, owner, test procedure and evidence type. Use ISO/IEC 27001:2022 Annex A, with its 93 controls, as the spine, then attach PCI DSS v4.0.1 requirements and the eight Act 843 principles as many-to-many links. Keep requirement text verbatim for traceability and write interpretations in a separate field. Version every change, because regulators ask what you believed on a given date. Flag controls linked to many obligations as critical, since one failure then creates several findings.
Building a Breach Notification Matrix
Reporting duties differ in trigger, recipient and deadline. GDPR requires notifying the supervisory authority within 72 hours where feasible, unless the breach is unlikely to risk individuals. Ghana's Act 1038 provides for incident reporting, and sector directives such as the Bank of Ghana Cyber and Information Security Directive may add duties. Build a matrix with columns for regime, trigger condition, recipient, deadline, approver and template. Link it to the incident handling process described in NIST SP 800-61, so triage records the facts needed for each decision. Rehearse it in tabletop exercises, because the clock usually starts before legal teams are involved.
Glossary
Key Terms
- Obligation Register
- A structured list of every legal, regulatory and contractual requirement mapped to controls.
- Crosswalk
- A mapping that shows how one control satisfies clauses in several frameworks.
- Statement of Applicability
- An ISO/IEC 27001 document stating which Annex A controls apply and why.
- Control Drift
- The gradual decline of a control's operation after it was first implemented.
Related
Explore Connected Capabilities
Proof Points
What We Can Stand Behind
- Every stage of DAAKYI's delivery methodology produces documented, auditable deliverables.
Technology partners
FAQ
Questions Leaders Ask
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