> Document Version: 1.0 Document Owner: Acme Inc Next Review Date: 2027-03-19

Organization: Acme Inc

Generated: 2026-03-19

Detected Services: 8 across 7 categories

Current Maturity Level: Optimizing (Level 5/5)

## Executive Summary

This 12-month roadmap provides a structured plan to build and mature Acme Inc's privacy program from its current state (Level 5: Optimizing) toward full compliance maturity.

### Current Maturity Assessment

    Current Level: █████ 5/5
    Target (6mo):  █████ 5/5
    Target (12mo): █████ 5/5

Current state: Continuous improvement. Privacy by design culture.

### Roadmap at a Glance

Quarter | Focus | Key Milestones
--- | --- | ---
Q1 (Months 1-3) | Foundation | Privacy policy, consent, breach procedures
Q2 (Months 4-6) | Operationalize | Vendor management, training, DSAR process
Q3 (Months 7-9) | Mature | Automation, metrics, audit readiness
Q4 (Months 10-12) | Optimize | Continuous improvement, certification prep

## Q1: Build the Foundation

### Month 1: Privacy Governance & Core Documents

Theme: Establish governance and publish essential documents.

#### Week 1-2: Governance Setup

- Appoint a privacy lead — Current: Jane Mueller
- Define privacy program scope — Document which systems, data, and teams are in scope
- Conduct initial data inventory — Map all 8 detected services and their data flows
- Establish privacy team — Identify stakeholders from Legal, Engineering, Product, and Security

#### Week 3-4: Core Document Review & Publication

- Review and publish Privacy Policy — Verify all 8 services are listed
- Review and publish Terms of Service — Customize for your business model
- Publish Security Policy — Include responsible disclosure contact
- Publish AI Disclosure — EU AI Act Art. 50 transparency requirement
- Deploy cookie consent mechanism — ePrivacy Directive compliance
- Publish Refund Policy — EU consumer rights compliance

#### Month 1 Deliverables

Deliverable | Status | Owner | Deadline
--- | --- | --- | ---
Privacy lead appointed | ☐ | Executive team | Week 1
Data inventory complete | ☐ | Privacy lead | Week 2
Privacy Policy published | ☐ | Legal/Privacy | Week 3
Terms of Service published | ☐ | Legal | Week 3
Security Policy published | ☐ | Engineering | Week 4

### Month 2: Data Protection & Incident Readiness

Theme: Establish breach response and data protection procedures.

#### Week 5-6: Incident Response

- Finalize Incident Response Plan — Define roles, escalation paths, and timelines
- Set up breach notification templates — Pre-draft notifications for regulators and users
- Establish incident communication channels — On-call rotation, dedicated Slack/Teams channel
- Conduct first tabletop exercise — Simulate a breach scenario with the response team
- GDPR 72-hour notification procedure — Document the process to notify supervisory authority

#### Week 7-8: Data Protection

- Document data retention periods — Define retention for each of the 7 data categories
- Implement automated deletion — Set up cron jobs or TTLs for data that exceeds retention periods
- Review Data Processing Agreements — Ensure DPAs are in place with all 8 sub-processors
- Database encryption audit — Verify encryption at rest for all database services

#### Month 2 Deliverables

Deliverable | Status | Owner | Deadline
--- | --- | --- | ---
Incident Response Plan | ☐ | Security | Week 5
Tabletop exercise complete | ☐ | Security | Week 6
Data retention schedule | ☐ | Privacy lead | Week 7
DPAs collected | ☐ | Legal | Week 8

### Month 3: Consent & Rights Management

Theme: Implement data subject rights and consent management.

#### Week 9-10: Consent Architecture

- Cookie consent audit — Verify all cookies are categorized and consent is collected before non-essential cookies
- Consent banner testing — Test across browsers, devices, and regions
- Consent record keeping — Implement logging for all consent events (who, when, what, how)
- Privacy preference center — Build or configure a page where users can manage their preferences
- Consent withdrawal mechanism — Ensure users can easily withdraw consent

#### Week 11-12: Data Subject Rights

- DSAR handling process — Document the end-to-end process for data subject access requests
- Data export capability — Build or verify the ability to export user data in a portable format
- Account deletion flow — Implement self-service account deletion (GDPR Art. 17)
- Right to rectification — Enable users to correct their personal data
- Response time SLA — Commit to responding to DSARs within 30 days

#### Q1 Checkpoint

At the end of Q1, you should have:

- ✅ Published core legal documents
- ✅ Incident response plan tested
- ✅ DPAs with all sub-processors
- ✅ Consent management operational
- ✅ DSAR handling process live

Expected maturity: Level 5 (Managed)

## Q2: Operationalize Privacy

### Month 4: Vendor & Third-Party Management

Theme: Systematic vendor risk management.

- Complete vendor risk assessment — Evaluate each of the 8 detected services
- Vendor security questionnaire — Send SIG Lite questionnaire to all sub-processors
- Vendor onboarding process — Define approval workflow for new third-party services
- Sub-processor list publication — Publish and maintain a public list of sub-processors
- Vendor exit planning — Document migration strategies for critical services
- Sub-processor change notification — Set up process to notify users of sub-processor changes

### Month 5: Privacy Training & Awareness

Theme: Build a privacy-aware culture.

- Privacy training program — Develop role-specific training materials
- Engineering: secure coding, data minimization, privacy by design
- Product: privacy impact assessment, consent UX patterns
- Support: DSAR handling, data breach identification
- Management: regulatory landscape, liability, compliance budgeting
- Training records — Implement a system to track training completion
- Privacy champions network — Appoint privacy champions in each team
- Privacy newsletter — Launch an internal monthly privacy update
- Phishing simulation — Run a baseline phishing awareness test

### Month 6: Privacy Impact Assessments

Theme: Systematic risk identification.

- PIA/DPIA process — Document when and how privacy impact assessments are conducted
- AI impact assessment — DPIA for AI-based processing activities (GDPR Art. 35)
- Privacy by design checklist — Integrate privacy checks into the product development lifecycle
- Risk register update — Update the risk register with findings from all assessments
- Transfer impact assessment — Evaluate all international data transfers (Schrems II)
- Lawful basis review — Confirm the lawful basis for each processing activity

#### Q2 Checkpoint

At the end of Q2, you should have:

- ✅ Vendor management program operational
- ✅ Privacy training delivered to all staff
- ✅ PIAs completed for high-risk processing
- ✅ International transfer safeguards in place

Expected maturity: Level 5 (Optimizing)

## Q3: Mature the Program

### Month 7: Automation & Monitoring

Theme: Reduce manual effort, increase consistency.

- CI/CD compliance checks — Integrate Codepliant into your CI/CD pipeline

      # .github/workflows/compliance.yml
      - uses: joechensmartz/codepliant@v410
        with:
          fail-on-missing: true

- Pre-commit hook — Install compliance pre-commit hook

      npx codepliant hook install

- Automated dependency scanning — Weekly vulnerability scans
- Consent analytics dashboard — Track consent rates, opt-out rates, DSAR volumes
- Security event alerting — Configure alerts for suspicious patterns in monitoring data
- Scheduled re-scans — Weekly automated compliance scans

      npx codepliant schedule install --frequency weekly

### Month 8: Metrics & Reporting

Theme: Measure what matters.

- Define compliance KPIs — Establish key performance indicators:
- DSAR response time (target: <30 days)
- Consent rate (target: >80%)
- Training completion rate (target: 100%)
- Vendor DPA coverage (target: 100%)
- Incident response time (target: <24 hours)
- Document freshness (target: updated within 90 days)
- Executive dashboard — Monthly compliance report for leadership
- Compliance maturity score — Track progress toward target maturity level
- Regulatory readiness scorecard — Per-regulation compliance status
- Budget tracking — Monitor compliance program spend vs. budget

### Month 9: Audit Readiness

Theme: Prepare for external audit or certification.

- SOC 2 gap analysis — Identify gaps against Trust Service Criteria
- ISO 27001 readiness — Map controls to Annex A requirements
- Evidence collection — Gather evidence for all implemented controls
- Internal audit — Conduct a pre-audit internal review
- Record of processing activities — Verify GDPR Art. 30 documentation is complete
- Policy review cycle — Review and update all policies published in Q1

#### Q3 Checkpoint

At the end of Q3, you should have:

- ✅ Automated compliance checks in CI/CD
- ✅ KPI dashboard operational
- ✅ Internal audit completed
- ✅ All policies reviewed and updated

Expected maturity: Level 5

## Q4: Optimize & Sustain

### Month 10: Continuous Improvement

Theme: Embed privacy into daily operations.

- Privacy by design in SDLC — Mandatory privacy review for all new features
- Automated PIA triggers — Auto-trigger PIA when new services are added to codebase
- Privacy debt tracking — Track and prioritize privacy improvements alongside tech debt
- Cross-functional privacy reviews — Monthly meetings with Engineering, Product, Legal
- Industry benchmarking — Compare your program against industry peers

### Month 11: Advanced Compliance

Theme: Address specialized requirements.

- EU AI Act compliance — Complete AI governance framework implementation
- AI risk classification for all AI features
- Human oversight procedures for high-risk AI
- AI system logging and monitoring
- Conformity assessment documentation
- International compliance — Expand coverage to additional jurisdictions
- Data breach drill — Conduct annual breach response exercise
- Vendor re-assessment — Annual review of all sub-processor security
- Privacy program charter review — Annual review and update of program charter

### Month 12: Annual Review & Year 2 Planning

Theme: Reflect, report, and plan ahead.

- Annual compliance review — Complete the Annual Review Checklist
- Compliance certificate — Generate updated compliance attestation
- Annual report — Publish transparency report with DSAR/breach statistics
- Maturity re-assessment — Re-assess maturity level and document progress
- Year 2 roadmap — Plan next year's privacy program priorities based on:
- Regulatory changes (new laws, enforcement trends)
- Business changes (new products, markets, acquisitions)
- Technology changes (new services, AI capabilities)
- Audit findings and improvement opportunities
- Budget proposal — Submit compliance budget for next fiscal year

#### Q4 Checkpoint

At the end of Q4, you should have:

- ✅ Privacy embedded in development lifecycle
- ✅ Certification-ready documentation
- ✅ Annual review completed
- ✅ Year 2 roadmap approved

Target maturity: Level 5 (Optimizing)

## Resource Planning

### Estimated Effort by Quarter

Quarter | Engineering | Legal | Management | Total Hours/Week
--- | --- | --- | --- | ---
Q1 | 8-12 hrs/wk | 6-10 hrs/wk | 2-4 hrs/wk | 16-26
Q2 | 4-8 hrs/wk | 4-8 hrs/wk | 2-4 hrs/wk | 10-20
Q3 | 6-10 hrs/wk | 2-4 hrs/wk | 2-4 hrs/wk | 10-18
Q4 | 4-6 hrs/wk | 4-6 hrs/wk | 4-6 hrs/wk | 12-18

### Recommended Tools

Tool | Purpose | Priority
--- | --- | ---
Codepliant | Automated compliance doc generation | Essential
Cookie consent platform | Cookie consent management | Essential
DSAR management tool | Data subject request tracking | High
Vendor management platform | Third-party risk management | Medium
Training platform | Privacy training delivery | Medium

### Budget Estimate (Annual)

Category | Estimated Cost | Notes
--- | --- | ---
Tools & Software | $5,000-$20,000 | Compliance automation, consent management
Legal Review | $10,000-$30,000 | External counsel for policy review
Training | $2,000-$8,000 | Training platform and materials
Audit & Certification | $15,000-$50,000 | SOC 2 or ISO 27001 (if pursuing)
Personnel | Varies | Fractional DPO or dedicated privacy hire
Total | $32,000-$108,000 | Varies significantly by company size

## Success Criteria

### 12-Month Targets

Metric | Target | Measurement
--- | --- | ---
Privacy maturity level | Level 5 | Codepliant maturity assessment
Document coverage | 100% recommended docs | `codepliant completeness`
DSAR response time | < 30 days | DSAR tracking system
Consent rate | > 80% | Cookie consent analytics
Training completion | 100% of staff | Training record system
Vendor DPA coverage | 100% | Vendor management tracker
Incident response time | < 4 hours to triage | Incident response logs
Policy freshness | All updated within 90 days | `codepliant lint`

## Contact

Privacy Program Lead: Jane Mueller

Email: legal@acme.com

DPO Email: dpo@acme-saas.com

This Privacy Program Roadmap was generated by Codepliant based on automated analysis of 8 detected services at maturity level 5 (Optimizing). It should be reviewed and customized by a qualified compliance professional.