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

## Management Commitment Statement

### Acme Inc

Document ID: OATH-20260319-NEXTJSSAASEX

Effective Date: 2026-03-19

Project: nextjs-saas-example

> Important: This document is a statement of management commitment to information security and data protection compliance. It should be reviewed by legal counsel, signed by authorized executives, and maintained as a controlled document. This template is auto-generated and must be customized to reflect your organization's specific commitments.

## 1. Purpose

This Compliance Oath establishes the commitment of Acme Inc's senior management to:

- Maintaining an effective information security management system (ISMS)
- Protecting the personal data of our users, customers, employees, and partners
- Complying with all applicable data protection and privacy regulations
- Fostering a culture of security and privacy awareness throughout the organization
- Allocating adequate resources for compliance activities

## 2. Scope

This commitment applies to:

- Project: nextjs-saas-example
- Services covered: 8 third-party services across 7 categories
- Service categories: monitoring, auth, ai, analytics, database, email, payment
- Jurisdictions: EU, US-CA, US-VA, UK
- All employees, contractors, and third parties with access to systems or data

## 3. Management Commitment

The senior leadership of Acme Inc hereby commits to the following:

### 3.1 Information Security (ISO 27001 Clause 5.1)

- Leadership and Direction: Ensuring the information security policy and objectives are established and compatible with the strategic direction of the organization
- Integration: Ensuring information security requirements are integrated into the organization's processes
- Resources: Ensuring adequate resources are available for the ISMS
- Communication: Communicating the importance of effective information security management
- Outcomes: Ensuring the ISMS achieves its intended outcomes
- Continual Improvement: Directing and supporting persons to contribute to the effectiveness of the ISMS

### 3.2 Data Protection (GDPR Art. 5(2) Accountability)

- Lawful Processing: Ensuring all personal data processing has a valid legal basis
- Transparency: Maintaining clear and accessible privacy notices for all data subjects
- Data Minimization: Collecting only the data necessary for specified purposes
- Accuracy: Taking reasonable steps to ensure personal data is accurate and up to date
- Storage Limitation: Retaining personal data only for as long as necessary
- Integrity and Confidentiality: Implementing appropriate technical and organizational measures to protect personal data
- Accountability: Being able to demonstrate compliance with all data protection principles

## 4. Specific Commitments

### 4.1 Governance

Commitment | Frequency | Responsible
--- | --- | ---
Review and approve information security policy | Annually | CEO
Review compliance posture and risk register | Quarterly | CTO
Conduct management review of ISMS | Annually | CEO + CTO
Review and approve data processing activities | Annually | DPO
Audit third-party sub-processors | Annually | CTO
Review incident response readiness | Semi-annually | CTO
Approve compliance budget and resources | Annually | CEO

### 4.2 Resource Allocation

Management commits to providing:

- Personnel: Dedicated compliance/security resources appropriate to organization size
- Training: Annual security awareness training for all staff
- Tools: Industry-standard security and compliance tools
- External Support: Budget for legal counsel, auditors, and consultants as needed
- Incident Response: Resources for 24/7 incident response capability

### 4.3 Service-Specific Commitments

#### AI Systems

- Maintain an AI governance framework aligned with the EU AI Act
- Conduct AI impact assessments for all AI-powered features
- Ensure transparency in AI decision-making processes
- Provide human oversight mechanisms for automated decisions
- Review AI model cards and training data practices quarterly

#### Payment Processing

- Maintain PCI DSS compliance for all payment operations
- Never store raw credit card data on our systems
- Conduct quarterly vulnerability scans on payment-related systems
- Review payment processor agreements and DPAs annually

#### Analytics and Tracking

- Implement proper consent mechanisms before collecting analytics data
- Minimize data collection to what is strictly necessary
- Review analytics data retention policies quarterly
- Ensure analytics configurations respect user privacy preferences (DNT, GPC)

#### Authentication and Identity

- Implement industry-standard authentication practices (MFA, secure password hashing)
- Review access control policies quarterly
- Conduct access reviews for privileged accounts monthly
- Maintain audit logs for all authentication events

## 5. Regulatory Compliance

Management commits to compliance with the following regulations and frameworks:

Regulation / Framework | Applicability | Commitment
--- | --- | ---
GDPR (EU) | Personal data of EU residents | Full compliance with all articles
CCPA/CPRA (California) | Personal information of CA consumers | Full compliance with consumer rights
EU AI Act | AI systems used in the application | Risk assessment, disclosure, human oversight
PCI DSS | Payment card data processing | Maintain appropriate SAQ level
ISO 27001 | Information security management | Alignment with Annex A controls
SOC 2 | Service organization controls | Maintain Trust Service Criteria

## 6. Breach Response Commitment

In the event of a personal data breach, management commits to:

1. 72-hour notification to the relevant supervisory authority (GDPR Art. 33)
2. Undue delay notification to affected data subjects when the breach poses a high risk (GDPR Art. 34)
3. Full cooperation with supervisory authorities during investigations
4. Post-incident review within 14 days of any security incident
5. Remediation of root causes and implementation of preventive measures
6. Transparent communication with affected parties throughout the incident lifecycle

## 7. Continuous Improvement

Management commits to:

- Annual compliance audits (internal or external)
- Quarterly compliance reviews of policies and procedures
- Prompt remediation of identified compliance gaps
- Tracking regulatory changes and updating practices accordingly
- Benchmarking against industry best practices
- Incorporating lessons learned from incidents, audits, and industry events

## 8. Accountability

Role | Responsibilities
--- | ---
CEO | Overall accountability for compliance; approves policies, budget, and risk appetite
CTO | Technical implementation of security controls; infrastructure and application security
DPO | Monitoring compliance with data protection laws; advising on obligations; point of contact for supervisory authorities
Engineering Leads | Implementing security-by-design and privacy-by-design in development processes
All Employees | Following security policies; reporting incidents; completing training

## 9. Signatures

By signing below, the undersigned executives acknowledge their understanding of and commitment to the obligations described in this document.

### Chief Executive Officer

Field | Details
--- | ---
Name | _
Title | Chief Executive Officer
Date | 2026-03-19
Signature | _

### Chief Technology Officer

Field | Details
--- | ---
Name | _
Title | Chief Technology Officer
Date | 2026-03-19
Signature | _

### Data Protection Officer

Field | Details
--- | ---
Name | Jane Mueller
Title | Data Protection Officer
Email | dpo@acme-saas.com
Date | 2026-03-19
Signature | _

## 10. Review Schedule

Field | Details
--- | ---
Effective Date | 2026-03-19
Next Review Date | 2027-03-19
Review Frequency | Annually, or upon material changes to services or regulatory requirements
Document Owner | Acme Inc

## 11. Contact

For questions about this commitment or our compliance program:

- Email: legal@acme.com
- DPO: dpo@acme-saas.com
- Website: https://acme-saas.com

This Compliance Oath was auto-generated by Codepliant based on automated code analysis. It is a template document and must be reviewed, customized, and signed by authorized executives before it constitutes a binding commitment. Organizations should engage legal counsel to ensure this document meets their specific regulatory obligations.