Audit-ready GDPR programme stood up in four months.
Eleven priority gaps. Six-month clock. We took the DPO function on day one, rebuilt the programme around special-category data, and delivered a clean response pack to the supervisory authority in four months.
What landed on our desk.
A pharmaceutical group failed a regulator-prompted self-assessment with eleven findings classified as priority — six of them concerning special-category data flows across legal entities in seven jurisdictions.
The supervisory authority gave a six-month deadline to deliver a remediation pack. The internal data protection function had been vacant for four months. There was no DPIA inventory, no current Article 30 record, and an unmapped vendor estate of roughly 80 processors.
Five workstreams, one programme.
Took the role of named DPO of record across all entities. Single point of accountability to the authority for the duration of the engagement.
Mapped clinical, HR-health and pharmacovigilance flows first. Lawful bases re-grounded under Art. 9. Cross-entity transfers re-papered under Art. 46.
Eighty processors classified by risk and category. Article 28 DPAs renegotiated where required. Sub-processor chains documented end-to-end.
Drafted and submitted the response pack. Ran two formal authority sessions. Closed all eleven findings without conditional commitments.
Trained two senior internal hires into the run-state functions. Documentation handed over with an operating manual the authority had already accepted.
What changed, in numbers.
● VERIFIED · CLIENT-APPROVEDHow the work was set up.
Senior partner on the call, scoped engagement letter inside two weeks, named DPO from day one if that is the brief.