Data Protection

Compliance that holds up, not just on paper

Data protection has stopped being a legal checkbox and become an operational reality. Every contract you sign, every system you deploy, and every process that touches customer or employee data now carries GDPR obligations — and the gap between having a privacy policy and actually being compliant is where most organizations get caught out. Documentation without enforcement doesn’t protect you from a regulator, a breach, or a client’s due diligence questionnaire.

At Finagon, we help organizations close that gap. We build data protection frameworks that are genuinely embedded in how the business operates — so compliance holds up under real scrutiny, not just on the page.

Who This Is For

Our Data Protection service is built for:

• Companies without a mature GDPR compliance program, still relying on template policies that don’t reflect how data actually flows through the business
• Organizations handling sensitive personal, financial, or client data, where a breach or non-compliance carries significant reputational or regulatory risk
• Groups with multiple subsidiaries or business units, where data protection practices vary and there’s no consolidated oversight
• Businesses undergoing digital transformation, where new systems and tools are expanding the organization’s data footprint faster than governance can keep up
• Companies preparing for investment, partnership, or a transaction, where data protection due diligence is part of the process
• State-linked or regulated entities that need a defensible, audit-ready data protection posture

What We Help You Solve

• Policies that don’t match practice. A privacy policy exists, but no one has mapped what data is actually collected, where it’s stored, or who has access.
• No data protection officer or unclear ownership. Responsibility for compliance is informal or undefined, leaving no one accountable when issues arise.
• Third-party and vendor risk. Data is shared with processors, contractors, or cloud providers without proper agreements or oversight.
• Weak breach readiness. There’s no tested process for detecting, containing, and reporting a data breach within GDPR’s 72-hour window.
• Inconsistent practices across subsidiaries. Different business units handle data protection differently, creating group-wide exposure.
• Data protection as an afterthought in digital projects. New systems, websites, or tools are built and only reviewed for privacy compliance after launch — or not at all.

Our Approach

We structure Data Protection engagements around four phases, scaled to your organization’s size and risk profile.

1. Map

We identify what personal data your organization actually collects, processes, and stores — across systems, departments, and subsidiaries — and how it flows from collection to deletion. This includes reviewing existing policies, contracts, and technical safeguards against what’s really happening in practice.

2. Assess

We evaluate your current position against GDPR and applicable Bulgarian data protection law, identifying gaps in legal basis, consent mechanisms, retention practices, vendor agreements, and technical and organizational security measures. We prioritize findings by risk, so leadership knows what needs attention first.

3. Build

We design and implement the framework needed to close the gaps: privacy policies and notices that reflect actual practice, data processing agreements with vendors, records of processing activities, breach response procedures, and — where required — a data protection officer function or equivalent oversight role.

4. Sustain

Compliance isn’t a one-time project. We help train staff, establish ongoing monitoring and audit processes, and set up the governance needed to keep the framework current as your business, systems, and regulations evolve.

What’s Included

Depending on the scope of your engagement, Data Protection can include:

• Data mapping and processing activity audits
• GDPR and Bulgarian data protection law compliance gap assessment
• Privacy policy, cookie policy, and data notice drafting
• Data processing agreements and vendor/third-party risk review
• Data protection officer (DPO) function design or outsourced support
• Breach response planning and incident readiness testing
• Data protection impact assessments (DPIAs) for high-risk processing
• Staff training and awareness programs
• Group-wide data governance frameworks for multi-subsidiary organizations

Why Finagon

We build compliance that’s operational, not decorative. Our approach goes beyond drafting policy documents — we map actual data flows and build frameworks designed to function under real business conditions, not just look complete in an audit file.

We understand data protection alongside broader governance and risk. Data protection doesn’t sit in isolation from internal controls, procurement, and audit — we bring the same governance rigor we apply across our Risk and Compliance work to how we handle data protection specifically.

We’re comfortable with group-wide complexity. Designing consistent data protection standards across multiple subsidiaries or business units is a common challenge in our work, not an edge case.

We prepare you for scrutiny, not just self-assessment. Whether it’s a regulator, an investor’s due diligence team, or a client’s security questionnaire, we build frameworks designed to hold up when someone else is asking the questions.

How We Start

Every engagement begins with understanding your actual data footprint and where the real exposure lies. Tell us briefly about your data protection challenge — a compliance gap you suspect, a framework you need to build, or scrutiny you’re preparing for — and we’ll come back with an initial perspective on how to approach it.