Data Strategy pillar tips

Operational data governance aligned to law and engineering reality

Apply these steps to synchronise Zeph Tech research with EU Data Act obligations, TEFCA participation, ISO 8000 data quality requirements, and state privacy statutes.

Treat each section as a sprint backlog that keeps inventories, contracts, and technical safeguards verifiable.

Data inventory and classification

  • System-of-record mapping. Catalogue applications, datasets, and interfaces with ownership, lawful basis, retention, and residency attributes; align to GDPR Article 30 and LGPD Article 37 records.
  • Sensitive data tiers. Tag personal, health, financial, and trade-secret data with handling rules referencing HIPAA, PCI DSS, and ISO/IEC 27018 where applicable.
  • Access request readiness. Maintain request templates, validation procedures, and fulfilment SLAs for GDPR, CPRA, Virginia CDPA, and India DPDP Act rights.

Portability and interoperability

  • Cloud switching playbooks. Document export formats, encryption controls, and rollback testing aligned to EU Data Act Articles 23–27, including fee phase-out tracking.
  • Rehearse model contractual clauses. Use the Commission templates summarised in Zeph Tech’s October 20, 2025 Data Act briefing to validate exit support, Article 41 fair-terms commitments, and interoperability guardrails with sourcing and product owners.
  • Healthcare interoperability. Implement HL7 FHIR R4 APIs, Prior Authorization API requirements, and TEFCA Qualified Health Information Network agreements with monitoring dashboards.
  • Financial data pipelines. Align ISO 20022 messaging upgrades, SWIFT migration milestones, and BCBS 239 aggregation metrics with treasury and risk reporting.

Contracting and sharing controls

  • Update legal templates. Refresh DPAs, joint-controller agreements, and data-sharing contracts with references to EU Data Act fairness clauses, ANPD standard contractual clauses, and UK ICO guidance.
  • Third-country safeguards. Document transfer impact assessments, supplementary measures, and derogations per EDPB Recommendations 01/2020 and UK IDTA requirements.
  • Sector gateways. Configure data intermediary registrations, data altruism consents, or TEFCA participant directories with compliance monitoring and dispute workflows.
  • Block non-compliant new contracts. Follow the October 1, 2025 Chapter IV compliance briefing to inventory agreements signed after 12 September 2025, embed fair-terms attestations, and drill switching support before signature.

Data quality and lifecycle

  • Define metrics. Establish accuracy, completeness, timeliness, and traceability KPIs tied to ISO 8000-8 and ISO 5259-4 guidelines; publish scorecards to governance forums.
  • Remediation workflow. Route data quality issues to accountable owners with remediation deadlines, root-cause analysis, and audit trails stored in ticketing or lineage tooling.
  • Retention execution. Automate deletion and archiving schedules for each jurisdiction, aligning with CBAM, CSRD, HIPAA, and tax authority recordkeeping requirements.

Security and privacy engineering

  • Data minimisation. Embed minimisation checks in pipelines, preventing unnecessary attributes from entering data lakes and analytics platforms.
  • Encryption and key management. Enforce TLS 1.2+, at-rest encryption, and hardware security modules in line with NIST SP 800-57 and ENISA cloud security recommendations.
  • Monitoring and breach response. Integrate anomaly detection, logging, and incident response triggers aligned to GDPR Articles 33/34, LGPD deadlines, and U.S. sectoral breach rules.

Reporting and assurance

  • Board dashboards. Deliver quarterly updates on data incidents, portability readiness, DPDP consent volumes, and TEFCA uptime to executive sponsors.
  • Regulatory submissions. Prepare CSRD, CBAM, HTI-1 certification, and ANPD reporting packages with supporting evidence and sign-off matrices.
  • Audit coordination. Maintain documentation for internal audit, external assurance (ISAE 3000), and regulator examinations, including lineage diagrams and sample extracts.