Standard operating procedure · LG9C · Legal

Breach Response

Transactional procedure owned by Privacy & Data Protection in Legal. 7 numbered steps, 3 of them a person deciding and 4 of them agent work … more

Legal manual Service view

Procedure code

LG9C

Transactional

Rule versions in force

v5.8 · v4.4 · v4.8

4 governing rules stacked over it

In force since

2025-06-15

Earliest effective date across those rules

Last reviewed

2026-07-22

Latest review date across those rules

Rules approved by

Data Protection Officer

Rule health

3/4

1 under review · 0 superseded

There is no document register behind this header. The version, the dates and the approver names are read off the governing rules this procedure runs inside, which is the closest thing the estate holds to a document control record. Nobody wrote these procedures. There is no document library behind this page and no Word file anywhere in the estate. Every procedure below is generated from rows this platform already holds: the line and its ordered stations, the owning team and the person accountable for it, the policy items bound to that team, and the governance gates seeded against the function. The steps, the owners, the gates, the approvers, the dwell times and the volumes are read straight off those rows. The sentences that join them together are generated. Read a procedure as the estate describing itself, not as a document somebody signed.

Purpose and scope

What this procedure is for and where it stops

To run breach response to one repeatable standard inside Privacy & Data Protection, part of Legal. more

Entry condition

Runs transactional. Starts when an upstream system posts an event.

Exit condition

The unit clears post-mortem. more

In scope

Every unit of breach response raised inside Privacy & Data Protection, from the trigger below through to the final step.
4 of the 7 steps, which run without a person present.
3 decisions that stop the line until a named person releases it.

Out of scope

Anything outside the envelope set by the owning team. It leaves the line at a gate and becomes the named approver's decision.
Work that belongs to another function. This line hands off to information-technology and does not follow the unit there.
Shared-spine work. This line has none; every step is done inside the function.

Who owns it

Runs the line

Privacy Orchestrator

Accountable person

Data Protection Officer

The end of the escalation path. Above them sits Legal Chief of Staff for the function.

That team’s remit

Owns privacy case work end to end inside Legal. more

That remit describes the whole team, not this one procedure, so its counts are larger than the ones on this page.

Autonomy

61% now · ceiling 70%

Subject requests are located and assembled autonomously against a statutory clock. more

The procedure, step by step

7 numbered steps · 3 of them stop for a person

A step is one station on the line. more

No.	Step	Who does it	What happens	System of record	Time on the step	In flight
01	Detect Agentworkflow	Data Subject Request Agent	Data Subject Request Agent performs this step unattended at the workflow layer, inside the envelope its owning team has set, and writes an evidence record naming the actor, the authority it acted under and the digests of what it read and wrote.Hands off to information-technology	Contract Lifecycle Management	2.3 hrsstandard 4.3 hrs	20
02	Triage severity Agentworkflow	Processing Register Agent	Processing Register Agent performs this step unattended at the workflow layer, inside the envelope its owning team has set, and writes an evidence record naming the actor, the authority it acted under and the digests of what it read and wrote.	Document and Matter Management	2.0 hrsstandard 4.0 hrs	11
03	Contain Agentworkflow	Impact Assessment Agent	Impact Assessment Agent performs this step unattended at the workflow layer, inside the envelope its owning team has set, and writes an evidence record naming the actor, the authority it acted under and the digests of what it read and wrote.	Contract Lifecycle Management	1.3 hrsstandard 1.7 hrs	28
04	Assess notifiability HumanpolicyDecision	Data Protection Officer Releases: Data Protection Officer	Work stops. Data Protection Officer reviews what the line has produced and either releases the unit or sends it back. Nothing downstream of this step runs until that decision is made.Holds until: Held for a named human when the unit exceeds the privacy case decision envelope, when confidence falls below the floor, or when a policy clause is engaged.	Contract Lifecycle Management	2.3 hrsstandard 5.2 hrs	7
05	Regulator notify HumanpolicyDecision	Data Protection Officer Releases: Data Protection Officer	Work stops. Data Protection Officer reviews what the line has produced and either releases the unit or sends it back. Nothing downstream of this step runs until that decision is made.Holds until: Held for a named human when the unit exceeds the privacy case decision envelope, when confidence falls below the floor, or when a policy clause is engaged.	Contract Lifecycle Management	2.5 hrsstandard 5.7 hrs	3
06	Subject notify HumanpolicyDecision	Data Protection Officer Releases: Data Protection Officer	Work stops. Data Protection Officer reviews what the line has produced and either releases the unit or sends it back. Nothing downstream of this step runs until that decision is made.Holds until: Held for a named human when the unit exceeds the privacy case decision envelope, when confidence falls below the floor, or when a policy clause is engaged.	Contract Lifecycle Management	4.6 hrsstandard 6.1 hrs	6
07	Post-mortem Agentworkflow	Privacy Policy Agent	Privacy Policy Agent performs this step unattended at the workflow layer, inside the envelope its owning team has set, and writes an evidence record naming the actor, the authority it acted under and the digests of what it read and wrote.	Document and Matter Management	1.9 hrsstandard 2.7 hrs	42

The swimlane

The same steps, laid out by who is holding the work

Three lanes: a person deciding, an agent working, and the shared services spine. more

Person3 stations and 56% of the dwellAgent4 stations and 44% of the dwellShared spine0 stations and 0% of the dwell2 crossings between lanes

Human

decides

Agent

does the work

GBS

shared spine

System

attributed by rule

Contract Lifecycle Management

Document and Matter Management

Contract Lifecycle Management

Document and Matter Management

Click any station to see who does it, what it costs in time, the rule that gates it and the system attributed to it.

Run the procedure

One unit walked along that swimlane on the happy viable agentified path

Press run and a single unit enters at station 01. Each station takes exactly the dwell this platform records for it and is held by whoever the estate says holds it. more

speed

worked clock

00:00

allowance clock

00:00

stations cleared

0/7

the happy path, worked time0 min of 17 hrs

the same run against its allowance0 min of 30 hrs

Human

decides · 3

Agent

does the work · 4

GBS

shared spine · 0

run log

Nothing has happened yet. more

where the worked time goes17 hrs a unit

Person9.4 hrs · 56%Agent7.4 hrs · 44%2 crossings between lanes

what makes this path viable

The lanes are the recorded lanes. 3 of the 7 stations stop for a person and every one of them still does on this run.
Every one of the 3 decisions is still taken by the people who hold them. The happy path is that each one is released first time, not that it is skipped.
The owning team is held to a 70% autonomy ceiling and this run sits at 44% unattended, inside it.
2 systems are attributed across the stations, and 0 of them are connected. Nothing in this run has been watched executing against a real system of record.

what would have to change

1 of the 3 decisions can be handed over inside the 70% ceiling. more

could move to the agent lane

04 Assess notifiability — held by Data Protection Officer, 2.3 hrs a unit

stays with a person

05 Regulator notify — Handing this over would put 61% of the worked time in the unattended lane, past the 70% ceiling this team is held to.
06 Subject notify — The last decision on the line. Something on every procedure ends with a person, so this one is never offered.

what this run is, and what it is not

This is a run, not a forecast. more

Happy means nothing goes wrong: no station raises an exception, no gate sends the unit back, no rework loop fires and nothing sits in a queue between stations. more

The second clock is the allowance. more

A decision may be handed to the agent lane only if two things hold … more

The run reads the station rows only. more

What this run does not model: arrival patterns, contention between procedures for the same person, shift patterns, weekends, learning curves, and the cost of anything. more

Run it again, going wrong

The same unit, the same stations, broken the way the estate already records breaking

This is the same unit on the same stations, breaking. more

No break below was chosen. more

One play head, two tracks, the same scale. The clean run stops when it runs out of stations; the other one keeps going.

As written

7 stations, nothing waiting, nothing sent back

0 min of 17 hrs

now Detect · Data Subject Request Agent · 2.3 hrs

As the ledger has it

the same stations, plus 4 categories the estate already counts

0 min of 34 hrs

now Detect · Data Subject Request Agent · 2.3 hrs

personagentshared spinework the break addsnobody working it

What breaks, and where it is counted

No break below was chosen. more

What the two runs say together

4 counted categories land on this procedure. more

What this run cannot claim

These breaks are shown together on one unit so the shape of a bad day fits on one screen. more

Attestations on this estate are written against intake items, not against procedures, so a step done off the platform cannot be matched to the attestation that covers it. more

Two clocks run. Worked time is the sum of the time the work is actually being done … more

Roles and responsibilities

6 named parties

The responsibility grid is assigned by a rule, not lifted from a chart. more

Party	RACI	Steps	Duty	Escalates to
Privacy Orchestrator orchestrator	Runs the line	0	Sequences this line, holds its timetable and decides what has to surface to a person. more	Raises to Data Protection Officer when a unit falls outside the envelope or confidence drops below the floor.
Data Subject Request Agent agent A2% autonomy · ceiling A2% 90% clean · 3% overridden	Responsible	1	Runs the repeatable portion of privacy & data protection inside the shared transaction spine at spine cost and spine controls.	Escalates to Data Protection Officer when the unit falls outside the decision envelope or confidence drops below the floor.
Processing Register Agent agent A2% autonomy · ceiling A2% 95% clean · 7% overridden	Responsible	1	Executes the privacy & data protection step it owns, posts its evidence, and hands the unit to the next stage.	Escalates to Data Protection Officer when the unit falls outside the decision envelope or confidence drops below the floor.
Impact Assessment Agent agent A2% autonomy · ceiling A2% 93% clean · 7% overridden	Responsible	1	Executes the privacy & data protection step it owns, posts its evidence, and hands the unit to the next stage.	Escalates to Data Protection Officer when the unit falls outside the decision envelope or confidence drops below the floor.
Data Protection Officer person	Accountable and responsible	3	Holds 3 decisions on this line. more	Accountable to Data Protection Officer for the decisions held here.
Privacy Policy Agent agent A2% autonomy · ceiling A2% 96% clean · 16% overridden	Responsible	1	Holds the rules that bind every other agent in privacy & data protection. more	Escalates on any decision that would breach a live policy version, with the clause cited.

Decision points and escalation

3 places this procedure stops

04 · Assess notifiability

2.3 hrs

Held for a named human when the unit exceeds the privacy case decision envelope, when confidence falls below the floor, or when a policy clause is engaged.

Data Protection Officer

05 · Regulator notify

2.5 hrs

Held for a named human when the unit exceeds the privacy case decision envelope, when confidence falls below the floor, or when a policy clause is engaged.

Data Protection Officer

06 · Subject notify

4.6 hrs

Held for a named human when the unit exceeds the privacy case decision envelope, when confidence falls below the floor, or when a policy clause is engaged.

Data Protection Officer

Handoffs out of this procedure

Step 01 Detect passes the work to information-technology.

The rules this procedure runs inside

4 governing rules

Privacy & Data Protection Decision Envelope

active

LG9-POL-200 · envelope · vv5.8

Agents in this lane may act without a human when the privacy case sits inside the stated value, risk and confidence envelope. more

Approved by Data Protection Officer · in force 2025-09-27 · reviewed 2026-06-03

Binds Data Subject Request Agent, Processing Register Agent, Impact Assessment Agent, Vendor Data Terms Agent, Breach Triage Agent

LATAM · US

Privacy & Data Protection Evidence Standard

under review

LG9-POL-201 · evidence · vv4.4

Every autonomous decision writes inputs, the rule version applied, the model and prompt version, the output and a reversal path. more

Approved by Data Protection Officer · in force 2025-06-15 · reviewed 2026-06-27

Binds Data Subject Request Agent, Processing Register Agent, Impact Assessment Agent, Vendor Data Terms Agent, Breach Triage Agent

EU · UK · US

Privacy & Data Protection Escalation Rule

active

LG9-POL-202 · escalation · vv4.8

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. more

Approved by Data Protection Officer · in force 2026-01-09 · reviewed 2026-07-22

Binds Data Subject Request Agent, Processing Register Agent, Impact Assessment Agent, Vendor Data Terms Agent, Breach Triage Agent

Global · EU

Privacy & Data Protection Autonomy Ceiling

active

LG9-POL-203 · ceiling · vv4.8

The ceiling for this lane is 70 on the platform scale. more

Approved by Data Protection Officer · in force 2026-02-10 · reviewed 2026-05-28

Binds Data Subject Request Agent, Processing Register Agent, Impact Assessment Agent, Vendor Data Terms Agent, Breach Triage Agent

US · Canada

Systems this procedure touches

2 named · 0 connected

System attribution is a rule, not a reading. more

System	Vendor	Domain	Criticality	Steps	Connection
Contract Lifecycle Management	Icertis	legal	high	5	modeled
Document and Matter Management	iManage	legal	medium	2	modeled

0 of the 2 systems on this procedure is connected to the platform, and none of the twenty-six in the estate register is. 1 of them are marked as taking a write back, which is a property of the system, not a live path from here.

How it performs

End to end

16.9 hrs

Summed from the time each step sits, standard 29.7 hrs — running at 57% of the standard.

Touchless

65%

Agent share

57%

A week

1,669

In flight

117

Effort a week

566 human minutes · 446 agent minutes

Volume multiplied by the time on each step. more

Assurance over this procedure

4 governance gates sit above it

The twenty-four controls and eighteen exception classes in this platform are held at estate level … more

Gate	What trips it	Who releases it	Clock	Waivable
Any external legal communication approval	Every communication leaving the enterprise on a legal matter	Named lawyer	Same day	No
Contract above $250,000 approval	Contract value above $250,000 or nonstandard indemnity, unlimited liability or IP transfer	General Counsel delegate	2 business days	No
Settlement or regulator filing approval	Any settlement, filing or regulator submission	General Counsel	Case dependent	No
Citation and provenance audit oversight	Every agent-produced document with external authority citations	Citation Verifier plus lawyer sign-off	Pre-release	No

Next to it on the same team

Privacy & Data Protection

Data Subject Request

LG9A

Privacy Impact Assessment

LG9B

All of Legal

What this document is and is not

These procedures describe the modeled estate. more

Actions

What is waiting on a person

What one procedure document gives you, and what to check before you treat it as the standard.

151

named approvers appear across the library

Every decision point on every procedure carries a job title, not a queue. more

143

steps in the library hand their unit to another function

A handoff is where a procedure stops being one team’s problem. more

controls exist in the estate, and they belong to no procedure in particular

Controls and exception classes are held estate-wide. more

Operations

What this desk is allowed to start

A surface that only reports is not operable. more

Trigger and bound

A procedure document prints purpose, scope, entry and exit, the numbered steps with the actor on each, the roles and their RACI position, the swimlane, the decision points and escalation, the handoffs, the governing rules with version and approver, the systems by rule and the timings. more

Live observability

What the record shows right now

The whole library, by lane, so a single document can be read against the estate it came from. more

Current distribution

2,748 steps

Agent, inside the function1,38951%

Agent, on the shared spine85131%

Person deciding at a gate50818%

Is policy and strategy coming to fruition

Whether the written intent is holding here

Half. The document is complete and every actor on it is measured more

Not holding on the record

A procedure here carries a version, an approver, an in-force date and a last-review date. more