A data protection management plan is a document that outlines how an organization will protect its sensitive data from unauthorized access, use, disclosure, or loss. A data protection management plan should include the following components1:

The scope and objectives of the data protection management plan, and how it aligns with the organization’s data protection policy and strategy

The roles and responsibilities of the data protection team and other stakeholders, and how they will communicate and coordinate

The data protection risks and threats that the organization faces, and how they will be assessed and prioritized

The data protection controls and measures that the organization will implement and maintain, and how they will be monitored and evaluated

The data protection incidents and breaches that the organization may encounter, and how they will be reported and resolved

The data protection training and awareness programs that the organization will provide and conduct, and how they will be measured and improved

The first step that should be done when developing a data protection management plan is to identify critical data. This means that the organization should:

Define what constitutes sensitive data in the organization, such as personal data, confidential data, or regulated data

Identify and classify the sensitive data that the organization collects, processes, stores, or transfers, and assign appropriate labels or tags

Determine the value and importance of the sensitive data to the organization and its stakeholders, and the potential impacts or consequences of data loss or compromise

Map the data flows and locations of the sensitive data within the organization and across its partners or vendors, and document the data lifecycle stages and activities

By identifying critical data, the organization can:

Establish a clear and consistent understanding of the data protection scope and objectives, and ensure that they are relevant and realistic

Provide a comprehensive and accurate data inventory that can support the data protection risk assessment and control implementation

Identify and prioritize the data protection needs and requirements of the organization and its stakeholders, and align them with the data protection laws and standards

Communicate and report the data protection status and performance to the stakeholders and regulators, and ensure transparency and accountability

References = Guide to Developing a Data Protection Management Programme