Sub-function
Privacy & Data Protection
Owns privacy case work end to end inside Legal. Runs 3 lines across 21 stations, drains the repeatable share into the LEGAL tower, and holds 6 human gates.
Estate rating
BBB
72 / 100
Subject requests are located and assembled autonomously against a statutory clock. Notifiability is a judgment with regulatory penalties attached, so a named privacy officer decides.
Agents
9
Lines
3
Units / wk
5,925
Timetable vs actual
16.7h → 12.9h
Cost / unit
$14
was $33
Run-rate saving
$5.9M
annualized at this volume
The 9 agents running this sub-function
Grouped by what they are for, not by where they sit. The agent org is process-shaped.
Privacy Orchestrator
Owns the privacy & data protection lane end to end. Sequences the other agents, holds the timetable, and decides what surfaces to a human.
ceiling A2 · escalates to Escalates to Data Protection Officer when the unit falls outside the decision envelope or confidence drops below the floor.
Data Subject Request Agent
Runs the repeatable portion of privacy & data protection inside the shared transaction spine at spine cost and spine controls.
ceiling A2 · escalates to Escalates to Data Protection Officer when the unit falls outside the decision envelope or confidence drops below the floor.
Vendor Data Terms Agent
Runs the repeatable portion of privacy & data protection inside the shared transaction spine at spine cost and spine controls.
ceiling A2 · escalates to Escalates to Data Protection Officer when the unit falls outside the decision envelope or confidence drops below the floor.
Processing Register Agent
Executes the privacy & data protection step it owns, posts its evidence, and hands the unit to the next stage.
ceiling A2 · escalates to Escalates to Data Protection Officer when the unit falls outside the decision envelope or confidence drops below the floor.
Impact Assessment Agent
Executes the privacy & data protection step it owns, posts its evidence, and hands the unit to the next stage.
ceiling A2 · escalates to Escalates to Data Protection Officer when the unit falls outside the decision envelope or confidence drops below the floor.
Breach Triage Agent
Executes the privacy & data protection step it owns, posts its evidence, and hands the unit to the next stage.
ceiling A2 · escalates to Escalates to Data Protection Officer when the unit falls outside the decision envelope or confidence drops below the floor.
Cross-border Transfer Agent
Holds the rules that bind every other agent in privacy & data protection. Versions them, tests them against live decisions, and blocks work that breaches them.
ceiling A2 · escalates to Escalates on any decision that would breach a live policy version, with the clause cited.
Privacy Policy Agent
Holds the rules that bind every other agent in privacy & data protection. Versions them, tests them against live decisions, and blocks work that breaches them.
ceiling A2 · escalates to Escalates on any decision that would breach a live policy version, with the clause cited.
Privacy & Data Protection Challenger Agent
Adversarial reviewer for privacy & data protection. Argues the opposite case on every position and flags where the evidence does not carry the claim.
ceiling A2 · escalates to Escalates when a ratified position is still running against a break condition it flagged.
Estate rating breakdown
Seven control dimensions. Judgment readiness runs against autonomy on purpose.
People
What the humans stopped doing, and what they do now.
Redeployed into data stewardship and evidence quality.
Lines running in this sub-function
Each line is a workflow. Click a line to walk it station by station.
Strategy positions this sub-function holds
An agent that only executes is a robot. These are the calls it made, the argument against each one, and what would prove it wrong.
Privacy & Data Protection Operating Position
Draftv2Which parts of privacy & data protection should deliberately stay human, and how do we defend that against a cost argument?
Hold the ceiling at A2 for privacy & data protection. Subject requests are located and assembled autonomously against a statutory clock. Notifiability is a judgment with regulatory penalties attached, so a named privacy officer decides. Raise it only after two consecutive quarters where the override rate stays under five percent and every override has a written cause.
confidence
80%
The challenge — Privacy & Data Protection Challenger Agent
Privacy & Data Protection Challenger Agent argues the recommendation leans on 5 quarters of data from a period with no volume shock. The confidence band overlaps the alternative, and the position does not say what it would take to be wrong. Recorded as a dissent, not a block.
Break conditions
- ·Override rate rises above 12 percent for two consecutive months
- ·Cost per privacy case stops falling while volume keeps rising
- ·A control failure in this lane reaches a customer or a regulator
Evidence gaps
- ·No external comparator on a like-for-like unit definition
- ·Exception cases under $46k are sampled, not fully measured
| Alternative considered | Cost | Risk | Verdict |
|---|---|---|---|
| Hold the current position | $189k run rate | Known and priced. Cedes ground if comparators move faster. | live |
| Raise the ceiling one level now | $1549k to build controls | Override rate is 9 percent; raising the ceiling before that settles imports the error into production. | rejected on evidence |
| Move the exception tail to the spine | $985k transition | Loses local context. Rework risk on the cases that are hardest to recover. | under review |
Policy register
The rules the agents above are bound by. Version, owner, approver, and the agents each rule constrains.
| Ref | Rule | Scope | Owner agent | Approved by | Version | Status |
|---|---|---|---|---|---|---|
| LG9-POL-200 | Privacy & Data Protection Decision Envelope Agents in this lane may act without a human when the privacy case sits inside the stated value, risk and confidence envelope. Outside it, the unit holds at a gate with a named approver and a running clock. binds 5 agents · LATAM · US | envelope | Cross-border Transfer Agent | Data Protection Officer | v5.8 | Active |
| LG9-POL-201 | Privacy & Data Protection Evidence Standard Every autonomous decision writes inputs, the rule version applied, the model and prompt version, the output and a reversal path. An action with no evidence record is treated as a control failure, not a fast decision. binds 5 agents · EU · UK · US | evidence | Cross-border Transfer Agent | Data Protection Officer | v4.4 | under review |
| LG9-POL-202 | Privacy & Data Protection Escalation Rule Escalation is mandatory when confidence falls below the floor, when two options sit inside the confidence band, or when a break condition on a ratified position fires. Data Protection Officer owns the response clock. binds 5 agents · Global · EU | escalation | Cross-border Transfer Agent | Data Protection Officer | v4.8 | Active |
| LG9-POL-203 | Privacy & Data Protection Autonomy Ceiling The ceiling for this lane is 70 on the platform scale. Subject requests are located and assembled autonomously against a statutory clock. Notifiability is a judgment with regulatory penalties attached, so a named privacy officer decides. The ceiling is a governance decision, not a technical limit, and only Data Protection Officer can propose moving it. binds 5 agents · US · Canada | ceiling | Cross-border Transfer Agent | Data Protection Officer | v4.8 | Active |