> Auto-generated by Codepliant on 2026-03-19. Identifies single points of failure in compliance knowledge and provides cross-training recommendations. Review with leadership and HR to validate role assignments and implement mitigations. Document Version: 1.0 Document Owner: Acme Inc Next Review Date: 2027-03-19

## Executive Summary

Metric | Value
--- | ---
Key Compliance Roles | 7
Critical Roles | 3
Unassigned / Needs Assignment | 5
Single Points of Failure | 6

> Action Required: 5 role(s) need immediate assignment to avoid compliance gaps.

## Key Person Risk Matrix

Role | Risk Level | SPOF | Assigned | Backup
--- | --- | --- | --- | ---
Data Protection Officer (DPO) | 🔴 Critical | Yes | Yes | No
Security Lead / CISO | 🔴 Critical | Yes | No | No
Incident Response Lead | 🔴 Critical | Yes | No | No
Privacy Champion / Consent Manager | 🟠 High | Yes | No | No
AI Governance Lead | 🟠 High | Yes | No | No
Vendor Management Lead | 🟠 High | Yes | No | No
Compliance Training Coordinator | 🟡 Medium | No | No | No

## Role Details

### Data Protection Officer (DPO) 🔴

Description: Responsible for GDPR compliance oversight, DSAR handling, DPA review, supervisory authority liaison, and privacy impact assessments.

Risk Level: Critical

Single Point of Failure: Yes

Current Assignment: Jane Mueller (dpo@acme-saas.com)

Backup Assignment: [Assign backup DPO]

Cross-Training Recommendations:

- Train at least one backup team member on GDPR Articles 12-23 (data subject rights)
- Document all supervisory authority contacts and ongoing correspondence
- Create runbook for DSAR handling that any team member can execute
- Share DPA templates and vendor review procedures with legal team
- Schedule quarterly knowledge-sharing sessions on regulatory updates

Regulatory Implications if Unavailable:

- GDPR Art. 37-39: DPO must be accessible to data subjects and supervisory authorities
- If DPO is unavailable, DSAR response deadlines (30 days) may be missed
- Supervisory authority communications cannot be delayed — fines up to 4% of global revenue

### Security Lead / CISO 🔴

Description: Owns security policy, vulnerability management, penetration testing oversight, and security incident triage.

Risk Level: Critical

Single Point of Failure: Yes

Current Assignment: [Not formally assigned]

Backup Assignment: [Assign backup security lead]

Cross-Training Recommendations:

- Document all security tool access credentials in a shared vault
- Train backup on vulnerability scanning and patch management procedures
- Create incident classification guide that any engineer can use for initial triage
- Share penetration test scope and vendor contacts with at least two team members
- Maintain a security architecture document accessible to the engineering team

Regulatory Implications if Unavailable:

- SOC 2 Trust Service Criteria require documented security leadership
- ISO 27001 A.5.1 requires management commitment through security policy ownership
- Security incident response cannot wait for a single person to become available

### Incident Response Lead 🔴

Description: First responder for data breaches and security incidents. Coordinates containment, notification, and remediation.

Risk Level: Critical

Single Point of Failure: Yes

Current Assignment: [Assign incident response lead]

Backup Assignment: [Assign backup — must be available 24/7]

Cross-Training Recommendations:

- Conduct quarterly tabletop exercises with rotating team members as lead
- Document step-by-step breach notification procedures (supervisory authority + data subjects)
- Maintain up-to-date contact list for all sub-processors' security teams
- Train at least three team members on forensic evidence preservation
- Create pre-approved communication templates that any responder can send

Regulatory Implications if Unavailable:

- Breach notification timelines vary by jurisdiction
- Delayed incident response increases breach severity and regulatory exposure
- Multiple jurisdictions may require simultaneous notifications — single person cannot manage alone

### Privacy Champion / Consent Manager 🟠

Description: Manages consent management platform (CMP), cookie compliance, and tracking consent workflows.

Risk Level: High

Single Point of Failure: Yes

Current Assignment: [Assign privacy champion]

Backup Assignment: [Assign backup]

Cross-Training Recommendations:

- Document CMP configuration and how to update cookie categories
- Train marketing team on consent requirements before launching new campaigns
- Create checklist for adding new analytics or advertising services
- Share CMP admin access with at least two team members

Regulatory Implications if Unavailable:

- ePrivacy Directive: Invalid consent can result in immediate enforcement action
- GDPR Art. 7: Consent must be demonstrable — records must be maintained

### AI Governance Lead 🟠

Description: Oversees AI system classification, risk assessment, transparency obligations, and EU AI Act compliance.

Risk Level: High

Single Point of Failure: Yes

Current Assignment: [Assign AI governance lead]

Backup Assignment: [Assign backup]

Cross-Training Recommendations:

- Document AI system inventory with risk classifications
- Train engineering team on AI transparency requirements (Art. 50)
- Create checklist for evaluating new AI service integrations
- Share AI model documentation procedures with ML and product teams
- Conduct workshops on AI bias detection and fairness testing

Regulatory Implications if Unavailable:

- EU AI Act: High-risk AI systems require ongoing conformity assessment
- Colorado AI Act: Deployers must complete impact assessments
- AI governance decisions affect product roadmap — delays are costly

### Vendor Management Lead 🟠

Description: Manages relationships with 8 detected third-party services. Owns DPA negotiations, vendor risk assessments, and sub-processor monitoring.

Risk Level: High

Single Point of Failure: Yes

Current Assignment: [Assign vendor management lead]

Backup Assignment: [Assign backup]

Cross-Training Recommendations:

- Maintain a shared vendor contact database (see VENDOR_CONTACTS.md)
- Document DPA status and renewal dates for all vendors
- Train procurement team on security assessment requirements before onboarding new vendors
- Create vendor exit plan templates that any team member can execute

Regulatory Implications if Unavailable:

- GDPR Art. 28: Controller must ensure processor compliance
- Vendor incidents become your incidents — you need someone who can act immediately

### Compliance Training Coordinator 🟡

Description: Schedules and tracks mandatory compliance training for all employees. Maintains training records for audit evidence.

Risk Level: Medium

Single Point of Failure: No

Current Assignment: [Assign training coordinator]

Backup Assignment: [Assign backup]

Cross-Training Recommendations:

- Use a shared calendar with training schedule visible to all
- Automate training completion reminders
- Maintain training records in a shared, auditable system (see TRAINING_RECORD.md)
- Document the training curriculum so anyone can deliver sessions

Regulatory Implications if Unavailable:

- GDPR Art. 39(1)(b): DPO must assign awareness-raising and training
- SOC 2: Security awareness training must be documented for audits

## Bus Factor Analysis

The "bus factor" measures how many team members must be unavailable before a compliance function stops working.

Function | Current Bus Factor | Target Bus Factor | Gap
--- | --- | --- | ---
DSAR Handling | 1 | 3 | Train 2 additional team members
Breach Notification | 1 | 3 | Rotate incident response lead role quarterly
Vendor DPA Management | 1 | 2 | Share vendor contacts and DPA templates
Privacy Policy Updates | 1 | 2 | Document update procedure
AI Compliance | 1 | 2 | Cross-train product and engineering leads
PCI DSS Compliance | 1 | 2 | Train backup on PCI requirements

## 90-Day Action Plan

### Month 1: Assign and Document

- Assign all unassigned compliance roles
- Assign backup for every critical role
- Document all role responsibilities in an accessible location
- Create shared credential vault for compliance tools

### Month 2: Cross-Train

- Conduct first round of cross-training sessions
- Run tabletop exercise with backup responders
- Create runbooks for all critical compliance procedures
- Verify backup team members can access all required tools

### Month 3: Test and Validate

- Simulate DPO unavailability — can backup handle DSAR?
- Simulate security lead unavailability — can backup triage incident?
- Review and update all cross-training materials
- Schedule recurring cross-training (quarterly recommended)

This assessment is generated from automated code analysis and regulatory requirements. Actual key person risks depend on your organization's structure and team composition. Review with HR and leadership to validate.